Form 708 (draft) 708 (draft) United States Return of Tax for Gifts and Bequests Recei

TREASURY/IRS AND OMB USE ONLY DRAFT
Form

708

(December 2025)
Department of the Treasury
Internal Revenue Service

Part I

United States Return of Tax for Gifts and Bequests Received
From Covered Expatriates

OMB No. 1545-XXXX

Go to www.irs.gov/Form708 for instructions and the latest information.
For covered gifts or bequests received during calendar year 20
.

General Information (see instructions)

1 Recipient’s first name and middle initial, or name of trust

2 Recipient’s last name

3 Identifying number

4a Address (number and street). If you have a P.O. box, see instructions.

4b Apt. or suite no.

4c City, town, or post office. For foreign addresses, also complete lines 4f, 4g, and 4h.

4d State

4e ZIP code

4f Foreign country name

4g Foreign province/state/county

4h Foreign postal code

5 Name of fiduciary

6 Title of fiduciary

Did you receive a covered gift or covered bequest from a covered expatriate? If “Yes,” complete Part IV, Section 1 .

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8
9
10

Did you receive a distribution from a non-electing foreign trust? If “Yes,” complete Part IV, Section 2; and Part VI
Did you extend the date to file this Form 708? . . . . . . . . . . . . . . . . . . . .
Are you filing a protective Form 708? . . . . . . . . . . . . . . . . . . . . . . .

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11a
b
12

Are you an individual? If “Yes,” answer 11b, and go to line 16 . .
Check whether:
U.S. citizen
U.S. resident (noncitizen)
Are you a domestic trust? If “Yes,” go to line 14 . . . . . .

13a

Are you a foreign trust? If “Yes,” complete (as instructed) lines 13b–13f, and go to line 15

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b

Are you electing to be treated as a domestic trust pursuant to section 2801(e)(4)(B)(iii)? If “Yes,” go to line 15, and complete Part
VII and VIII . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

c

Do you already have a valid election in effect to be treated as a domestic trust pursuant to section 2801(e)(4)(B)(iii) for the current
year? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

d

If line 13c is “Yes,” enter the calendar year for which the Form 708 making the election was filed:

e
f

Are you terminating an election to be treated as a domestic trust pursuant to section 2801(e)(4)(B)(iii)? . . . . . . .
Has the identity or address of your U.S. agent changed since you last filed Form 708? If “Yes,” complete Part VII, Section 1

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14

Did you become a migrated foreign trust described in Reg. section 28.2801-4(a)(2)(iv) during this year? If “Yes,” complete Part
VII, Section 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

15

If line 13b or line 14 is “Yes,” did you receive a covered gift or covered bequest in a prior calendar year? If “Yes,” complete Part
IV, Section 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

16

Were gift or estate taxes paid to a foreign country with respect to covered gifts or covered bequests reported on this return? If
“Yes,” complete Part V . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part II

Tax Computation (see instructions)

1
2
3

Total value of covered gifts and bequests (from Part IV, Section 4, line 4)
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Amount of section 2801(c) exclusion for the calendar year. See instructions .
Taxable amount. Subtract line 2 from line 1 . . . . . . . . . .

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1
2
3

4
5
6

Tax. Multiply line 3 by 40% (0.40) . . . . . . . . . .
Foreign tax paid on covered gifts and bequests (from Part V, line 4)
Total tax. Subtract line 5 from line 4. If zero or less, enter -0- . .

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4
5
6

7
8

Amount paid with Form 7004

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7

9a

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Tax due. If the amount on line 6 is more than the amount on line 7, subtract line 7 from line 6. For details on how
to pay, go to www.irs.gov/Payments or see the instructions
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8

Overpayment. If the amount on line 7 is more than the amount on line 6, subtract line 6 from line 7. To elect direct
deposit for this amount, complete lines 9b, 9c, and 9d . . . . . . . . . . . . . . . . . .

9a

b

Routing number

d

Account number

Sign
Here

No

c Type:

Checking

Savings

Under penalties of perjury, I declare that I have examined this return, along with accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct,
and complete. Declaration of preparer (other than trustee or designated filer) is based on all information of which preparer has any knowledge.

Date

Signature

Paid
Preparer
Use Only

Preparer’s name

Preparer’s signature

Date

Firm’s name

PTIN

Firm’s EIN

Firm’s address

For Disclosure, Privacy Act, and Paperwork Reduction Act Notice,
see the instructions for this form.

Check
if
self-employed

Phone no.
Cat. No. 20230I

Form 708 (12-2025) Created 5/12/25

DRAFT — DO NOT FILE

DRAFT — DO NOT FILE

Yes
7

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Page 2

Form 708 (12-2025)

Part III

Covered Expatriates (see instructions)

If additional entries are needed, duplicate and use this page.
1

Enter the information for each covered expatriate from whom you received a covered gift or covered bequest, or a distribution attributable to a
covered gift or bequest, reported on this return.
(b)
Expatriation date

(c)
Identifying number

(d)
If deceased, date
of death

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(a)
Name

Form 708 (12-2025)

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Page 3

Form 708 (12-2025)

Part IV

Covered Gifts and Covered Bequests (see instructions)

If additional entries are needed, duplicate and use this page.

Section 1—Covered Gifts & Bequests (excluding Distributions From Non-Electing Foreign Trust)
1

Enter, in the order received, the covered gifts and covered bequests received during the calendar year.

(a)
Item number

(b)
Name of covered expatriate donor or decedent

(c)
28.2801-4(d)(8)
(ii) election for
future interests

(d)
Date of receipt

(e)
Description of covered gift or covered bequest

(f)
Value

A
A

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A
A
A
A
A
A
A
A
A
A
A
A
A
2
3

Add all amounts in column (f) . . . . . . . . . . . . . . .
Total from column (f) from additional Parts IV, Section 1, attached to this return

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2
3

4

Total covered gifts and covered bequests. Add lines 2 and 3. Enter here and on Part IV, Section 4, line 1

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Form 708 (12-2025)

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Form 708 (12-2025)

Part IV

Covered Gifts and Covered Bequests (see instructions) (continued)

If additional entries are needed, duplicate and use this page.

Section 2—Distributions from Non-Electing Foreign Trusts. Complete this section if you received a distribution from a non-electing foreign trust attributable to covered gifts or
bequests. You must first complete Part VI for each non-electing foreign trust from which you received a distribution.
1

Enter, in the order received, the distributions received during the calendar year.

(a)
Item number

(b)
Description of distributed property

(c)
Date of receipt
of distribution

(d)
Value of distribution

(e)
Section 2801 ratio on
date in column (c)
(from Part VI,
Section 2, column (h))

(f)
Value (multiply
column (d) by
column (e))

B
B

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B
B
B
B
B
B
B
B
B
B
B
B
B
2

Add all amounts in column (f)

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2

3
4

Total from column (f) from additional Parts IV, Section 2, attached to this return
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Total distributions from non-electing foreign trust. Add lines 2 and 3. Enter here and on Part IV, Section 4, line 2 .

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Form 708 (12-2025)

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Page 5

Form 708 (12-2025)

Part IV

Covered Gifts and Covered Bequests (see instructions) (continued)

If additional entries are needed for Section 3, line 1, duplicate and use this page.

Section 3—Covered Gifts or Bequests Received by Electing Foreign Trusts and Migrated Foreign Trusts in Prior Year(s). If you are or were a foreign trust, complete this
part to report covered gifts or bequests you received in a prior year if this is the initial calendar year for which: (1) you are making the election to be treated as a domestic trust for
purposes of section 2801, or (2) you are treated as a domestic trust as defined in section 7701(a)(30)(E).
1

Section 2801 Ratio. List the initial covered gift or bequest received by you, as a non-electing foreign trust, first, and then list all contributions you received subsequent to the initial covered gift
or bequest received as a non-electing foreign trust in chronological order.

(a)
(b)
Date of foreign Value of contribution
trust’s receipt
to foreign trust on
of contribution
date in column (a)

(c)
Pre-contribution
value of trust

(d)
Post-contribution
value of trust (add
column (b) and
column (c))

(e)
(f)
(g)
(h)
Value of covered gift or Section 2801 ratio
Pre-contribution value
Is
of covered gift or
contribution bequest. If column (f) is (divide column (g) by
bequest portion of a covered gift “Yes,” add column (b)
column (d))
trust (multiply column or bequest? and column (e). If “No,”
enter amount in
(c) by column (h) of
column (e).
previous line)*
(i)
(ii)

2

(j)
Description of covered gift
or bequest

No

Complete columns (b)–(e) below, to determine the value of covered gifts or bequests received by you, as a non-electing foreign trust in prior year(s).

(a)
Item number

(b)
Immediately preceding calendar year

(c)
Value of trust on Dec. 31 of year listed in
column (b)

(d)
Last Section 2801 ratio from line 1(h) above on
Dec. 31 of year listed in column (b)

(e)
Value (multiply column (c) by (d)). Include on Part IV,
Section 4, line 3.

C1

Section 4—Total Covered Gifts and Covered Bequests
1
2

Total value of Section 1—Covered Gifts and Covered Bequests. Enter amount from Part IV, Section 1, line 4 . . .
Total value of Section 2—Distributions from Non-Electing Foreign Trust. Enter amount from Part IV, Section 2, line 4 .

3

Total value of Section 3—Covered Gifts or Bequests Received by Electing Foreign Trusts and Migrated Foreign Trusts in Prior Year(s). Enter amount from Part IV,
Section 3, line 2, column (e) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4

Total value of covered gifts or bequests listed on Part IV. Add lines 1 through 3. Enter here and on Part II, line 1 .

* If this is your initial entry on line 1 and there is no previous column (h) with a ratio, enter zero (-0-).

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1
2
3
4
Form 708 (12-2025)

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Yes

(i)
Name of covered expatriate

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Page 6

Form 708 (12-2025)

Part V

Foreign Gift or Estate Taxes (see instructions)

If additional entries are needed, duplicate and use this page.
1

Complete for each item reported on Part IV for which you are claiming a reduction for foreign gift or estate taxes paid.
(b)

(c)

(d)

(e)

(f)

Item number

Value (from Part IV)

Date(s) of payment (if more than one, list separately)

Amount of foreign gift
or estate tax paid

Amount claimed or
allowed as refund

Subtract column (e)
from (d). If zero or
less, enter -0-.

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(a)

2

Add all amounts from column (f)

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2

3
4

Total from column (f) from additional Parts V attached to this return . . . . . . .
Total foreign gift or estate taxes paid. Add lines 2 and 3. Enter here and on Part II, line 5

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Form 708 (12-2025)

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Page 7

Form 708 (12-2025)

Part VI

Section 2801 Ratio for Distributions Received From Foreign Trust (see instructions)

If additional entries are needed, duplicate and use this page.
If you received a distribution from a non-electing foreign trust, complete and attach this Part VI for each non-electing foreign trust from which you received a distribution reported on Part IV. You must
attach the additional information required by the instructions.

Section 1—Foreign Trust Information
1 Name of distributing foreign trust

2 Name of trustee

3 Address (number and street). If you have a P.O. box, see instructions.

4 Apt. or suite no.

5 City, town, or post office. For foreign addresses, also complete lines 8, 9, and 10.

6 State

7 ZIP code

8 Foreign country name

9 Foreign province/state/county

10 Foreign postal code

(a)
(b)
Date of foreign Value of contribution
trust’s receipt
to foreign trust on
of contribution
date in column (a)

(c)
Pre-contribution
value of trust

(d)
Post-contribution
value of trust (add
column (b) and
column (c))

(e)
(f)
(g)
(h)
Value of covered gift or Section 2801 ratio
Pre-contribution value
Is
of covered gift or
contribution bequest. If column (f) is (divide column (g) by
bequest portion of a covered gift “Yes,” add column (b)
column (d))
trust (multiply column or bequest? and column (e). If “No,”
enter amount in
(c) by column (h) of
column (e).
previous line)*
(i)
(ii)
Yes

* If this is your initial entry on line 1 and there is no previous column (h) with a ratio, enter zero (-0-).

(i)
Name of covered expatriate

(j)
Description of covered gift
or bequest

No

Form 708 (12-2025)

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Section 2—Section 2801 Ratio. List the initial covered gift or bequest received by the foreign trust first, and then list all contributions received subsequent to the initial covered
gift or bequest received by the foreign trust in chronological order.

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Page 8

Form 708 (12-2025)

Part VII

U.S. Agent and Prior Distributions to U.S. Recipients (see instructions)

If additional entries are needed for Section 2, line 2, duplicate and use this page.

Section 1—U.S. Agent. Complete this part to provide or update information about your U.S. agent.
1 U.S. Agent’s first name and middle initial

2 U.S. Agent’s last name

3 TIN

4 Address (number and street). If you have a P.O. box, see instructions.
6 City, town, or post office

10
11

5 Apt. or suite no.
7 State

8 ZIP code

9 Phone number

Have you made the required designation of the above-named U.S. agent by filing Form 2848, Power of Attorney and Declaration of Representative? .

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If “Yes” to line 10, enter the date Form 2848 was filed. If “No,” a valid designation of a U.S. agent has not been made

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Yes

No

1
2

Check this box if you have not made any prior distributions to U.S. recipients attributable to covered gifts or bequests:
Enter prior distributions to U.S. recipients. You must first complete Part IV, Section 3, line 1, to determine your Section 2801 ratio.

(a)
Date of
distribution

(b)
Name of U.S. recipient

(c)
Address of U.S. recipient

(d)
TIN of U.S.
recipient

(e)
Description of distribution

(f)
Value of distribution

(g)
Section 2801 ratio on
date in column (a)
(from Part IV,
Section 3, line 1,
column (h))

(h)
Value of distribution
attributable to
covered gifts or
bequests (multiply
column (f) by
column (g))

Form 708 (12-2025)

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Section 2—Prior Distributions to U.S. Recipients. Complete this part to disclose all of your prior distributions to U.S. recipients attributable to covered gifts or bequests made
before: (1) if you are an electing foreign trust, the initial effective date of the domestic trust election made on this return, or (2) if you are a migrated foreign trust, the date that you
became a domestic trust.

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Page 9

Form 708 (12-2025)

Part VIII

Declaration of Foreign Trustee. Complete this part if you are electing to be treated as a domestic trust.

By my signature below, I, as the trustee of a foreign trust that is electing to be treated as a domestic trust pursuant to section 2801(e)(4)(B)(iii), hereby agree to timely file a
return to report each covered gift and covered bequest made to the trust in accordance with Reg. 28.2801-5(d)(3) and, under penalties of perjury, I declare that each
permissible distributee was notified that I am making (or have made) the election as of January 1 of the calendar year for which this Form 708 is filed.
1 Name of electing foreign trust

2 Signature

3 Title

4 Date
Form 708 (12-2025)

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DRAFT — DO NOT FILE

Name