Part IV—Covered Gifts and Covered Bequests

Complete Sections 1 and 2, as applicable. Complete Section 1 to report covered gifts and covered bequests you received during the applicable calendar year, not including those received as a distribution from a non-electing foreign trust. Complete Section 2 to report distributions you received during the applicable calendar year from non-electing foreign trusts attributable to covered gifts and covered bequests.

If you are an electing foreign trust or migrated foreign trust that checked “Yes” to Part I, line 15, complete Section 3 to report covered gifts and covered bequests that you received in a prior calendar year.

Instructions for Form 708 (12-2025) 11

Section 1—Covered Gifts and Covered Bequests (Excluding Distributions From Non-Electing Foreign Trusts) List in Section 1, line 1, each covered gift and covered bequest that you received during the applicable calendar year other than those received from a non-electing foreign trust. Also complete lines 2 through 4.

Line 1

List the required information for each covered gift and covered bequest chronologically in the order received. Duplicate and use page 3, Part IV, if additional entries are needed. See Covered gift and Covered bequest , earlier.

Column (a). Enter the item number, in the following format: A1, A2, A3, etc.

Column (b). Enter the name of the covered expatriate from whom you received the covered gift or covered bequest.

Column (c). If you elect to treat the date of receipt of a future interest in property not transferred or held in trust as the date of the gift (date of transfer), in the case of a covered gift, or the date of the covered expatriate’s death, in the case of a covered bequest check the box in column (c). See Election under Regulations section 28.2801-4(d)(8)(ii) for future interest not in trust under Date of receipt , earlier.

If you do not make that election, do not report the covered gift or covered bequest until you file the Form 708 for the year in which you receive the property.

Column (d). Enter the date you received the covered gift or covered bequest. If the box in column (c) is checked, enter the date of the gift of such future interest not in trust or the date of the covered expatriate’s death, as applicable. See Date of receipt , earlier.

Column (e). Describe each covered gift and covered bequest in enough detail so that the property can be easily identified.

Column (f). Enter the value of each covered gift or covered bequest as of the date of receipt. For additional information and supplemental documents, see Value of covered gift or covered bequest, earlier.

Section 2—Distributions From Non-Electing Foreign Trusts Prior to completing Section 2, you must complete Part VI. You must use Section 2 of Part VI to determine the section 2801 ratio on the date of each distribution from the foreign non-electing trust that you received during the applicable calendar year.

Line 1

List in Section 2, line 1, only distributions that you received during the applicable calendar year from non-electing foreign trusts. List each distribution of property from a non-electing foreign trust (regardless of the extent to which it is a covered gift or covered bequest) in the order received. Duplicate and use Part IV, Section 2, if additional entries are needed.

Column (a). Enter the item number as follows: B1, B2, B3, etc.

Column (b). Describe the property distributed to you from the non-electing foreign trust in enough detail so that the property can be easily identified.

Column (c). Enter the date you received the distribution from the non-electing foreign trust. In the event of a sale, encumbering, monetization or other disposition of a U.S. recipient’s interest in a non-electing foreign trust, the date of receipt is the date of such sale, encumbrance, monetization, or other disposition of the interest. See Date of receipt, earlier.

Column (d). Enter the value of the property distributed to you from the non-electing foreign trust on the date of receipt listed in column (c). For additional information and supplemental documents, see Value of covered gift or covered bequest, earlier.

Column (e). Enter the foreign trust’s section 2801 ratio in effect on the date you received the distribution from Part VI, Section 2, column (h).

Column (f). Multiply column (d) by the section 2801 ratio in column (e). This is the value of the distribution attributable to covered gifts and covered bequests and thus is the taxable value of the distribution you received from the non-electing foreign trust.

Section 3—Covered Gifts or Covered Bequests Received by Electing Foreign Trusts and Migrated Foreign Trusts in Prior Year(s) Complete Section 3, only if:

1. You were a non-electing foreign trust on December 31 of the prior calendar year;

2. You received a covered gift or covered bequest in a prior calendar year; and

3. You either:

a. Are making an election to be treated as a domestic

trust for purposes of section 2801 for the applicable calendar year; or

b. You became a domestic trust during the applicable

calendar year. See Migrated foreign trust, earlier.

Line 1. Section 2801 Ratio Complete this part to determine your section 2801 ratio as of December 31 immediately preceding the applicable calendar year. Your section 2801 ratio will be zero until the date you received a covered gift or covered bequest, at which time your section 2801 ratio must first be determined. After determination of your initial section 2801 ratio, your section 2801 ratio must be redetermined upon your receipt of each subsequent contribution.

Starting with the first covered gift or covered bequest you received, list all contributions you received, including distributions from other non-electing foreign trusts in the order received. Complete and attach a copy of Part VI for any distributions you received from another non-electing foreign trust and attach a copy of that trust’s governing instrument to this return.

Column (a). Enter the date that the trust received a contribution. The first contribution listed should be the initial covered gift or covered bequest received by the trust. Additional contributions you received, whether or not covered gifts or covered bequests, must be listed in the order

12 Instructions for Form 708 (12-2025)

received to redetermine your section 2801 ratio as of the date of each contribution received.

Column (b). Enter the fair market value of the contribution on the date received by you. See Value of covered gift or covered bequest, earlier.

Column (c). Enter the fair market value of all property in the trust immediately prior to receipt of the contribution. See Value of covered gift or covered bequest , earlier.

Column (d). Add column (b) and column (c) to get the post-contribution value of the trust, and enter the value in column (d). The post-contribution value of the trust is the fair market value of your assets immediately after your receipt of the contribution received on the date reported in column (a).

Column (e). Multiply column (c) by column (h) of the previous line to get the pre-contribution value of the covered gift or covered bequest portion of the trust, and enter the value in column (e). The pre-contribution value of the covered gift or covered bequest portion of the trust is the value of the trust attributable to covered gifts and covered bequests, if any, immediately before you received the contribution on the current line of this schedule. This value is determined by multiplying the fair market value of the trust’s assets by the section 2801 ratio in effect immediately prior to your receipt of that contribution.

Column (f). Check “Yes” when completing for the initial covered gift or covered bequest to the trust. For each subsequent contribution the trust received after the initial covered gift or covered bequest and on or before December 31 of the prior calendar year, check the appropriate box to indicate whether the contribution is a covered gift or covered bequest.

Column (g). The entry in column (g) is the post-contribution value of the covered gift or covered bequest portion of the trust.

For subsequent contributions, if the “Yes” box is checked in column (f), add the amount in column (b) and the amount in column (e), and enter the amount in column (g). Column (g) is the value of the covered gift or covered bequest portion of the trust arrived at by adding together the pre-contribution value of the covered gift or covered bequest portion of the trust and the value of the current covered gift or covered bequest received by such trust.

For subsequent contributions, if the “No” box is checked in column (f), enter the amount from column (e) in column (g). Column (g) will show the pre-contribution value of the covered gift or covered bequest portion of the trust as the value of the covered gift or covered bequest portion of the trust.

Column (h). Compute and enter the trust’s section 2801 ratio by dividing column (g) by column (d). Report this amount in column (h) and carry the computation to two decimal places (for example, .58).

Column (i). If the box in column (f) is checked “Yes,” enter the name of the covered expatriate making the gift or bequest, as applicable. For distributions received from another non-electing foreign trust attributable to covered gifts or covered bequests, enter the name of that trust. If the box in column (f) is checked “No,” leave this entry blank.

Column (j). If the box in column (f) is checked “Yes,” describe the covered gift or covered bequest in enough detail so that the property can be easily identified. For additional information and supplemental documents, see Value of

covered gift or covered bequest, earlier. If the box in column (f) is checked “No,” leave this entry blank.

Line 2 Complete line 2 of Part IV to determine the value of covered gifts or covered bequests you received as a non-electing foreign trust in prior calendar years.

Column (b). Enter the calendar year immediately preceding the applicable calendar year for which you are filing this Form 708.

Column (c). Enter the fair market value of the property you held in trust on December 31 of the year listed in column (b).

Column (d). Enter your last section 2801 ratio on the date listed in column (b), as computed on Section 3, line 1, column (h).

Column (e). Multiply column (c) by column (d). This is the value of the property you held in trust on December 31 of the immediately preceding calendar year that is attributable to covered gifts or bequests you received in prior calendar year(s).

Section 4—Total Covered Gifts and Covered Bequests Enter the total amount of the covered gifts and covered bequests reported on Sections 1–3 of Part IV. You must make an entry in each of lines 1–4. This is the total amount subject to tax under section 2801(a) for the applicable calendar year. If you did not report any covered gifts or covered bequests of the type specified by a given line, enter zero for that line.

Caution: Entering zero for any of lines 1–3 is a statement by you that you did not receive any transfers subject to tax under section 2801(a) covered by that line.