Schedule D. — Instruction 709 — Instructions for Form 709

Part 1—Generation-Skipping Transfers Enter in Part 1 all of the gifts you listed in Part 2 of Schedule A, in the same order and showing the same values. If reporting the GST portion of transfers subject to an ETIP, see How to report GSTs after the close of an ETIP, later.

Column (a)

List items from Schedule A, Part 2, column (a), in the same order. Next, list items to be reported on Schedule D (including ETIP transfers), if any.

20 Instructions for Form 709 (2025)

Column (b)

Only provide descriptions for ETIP transfers; otherwise, leave blank.

Column (d)

You are allowed to claim the gift tax annual exclusion currently allowable for your reported direct skips (other than certain direct skips to trusts—see Note below) using the rules and limits discussed earlier for the gift tax annual exclusion. However, you must allocate the exclusion on a gift-by-gift basis for GST computation purposes. You must allocate the exclusion to each gift, to the extent desired but not exceeding the maximum allowable amount, in chronological order, beginning with the earliest gift that qualifies for the exclusion. Be sure that you do not claim a total exclusion of more than $19,000 per donee.

Note: You may not claim any annual exclusion for a transfer made to a trust unless the trust meets the requirements discussed under Part 2 , earlier.

How to report GSTs after the close of an ETIP. If you are reporting a GST that occurred because of the close of an ETIP, complete Part 1 as follows.

Column (b). For transfers subject to an ETIP only, describe each transfer as provided in the instructions for Part 1 of Schedule A. In addition, describe the interest that is closing the ETIP, explain what caused the interest to terminate, list the date the ETIP closed, and list the year the gift portion of the transfer was reported and its item number on Schedule A that was originally filed to report the gift portion of the ETIP transfer.

Column (c).

If the GST exemption is being allocated on a timely filed (including extensions) gift tax return, enter the value as of the close of the ETIP.
If the GST exemption is being allocated on a late-filed (past the due date including extensions) gift return, enter the value as of the date the gift tax return was filed.

Part 2—GST Exemption Reconciliation (Section 2631)

Line 1

Every donor is allowed a lifetime GST exemption. The amount of the exemption for 2025 is $13,990,000. For transfers made through 1998, the GST exemption was $1 million. The exemption amounts for 1999 through 2025 are as follows.

Year Amount 1999 . . . . . . . . . . . . . . . . . . . . . . . . . $1,010,000 2000 . . . . . . . . . . . . . . . . . . . . . . . . . $1,030,000 2001 . . . . . . . . . . . . . . . . . . . . . . . . . $1,060,000 2002 . . . . . . . . . . . . . . . . . . . . . . . . . $1,100,000 2003 . . . . . . . . . . . . . . . . . . . . . . . . . $1,120,000 2004 and 2005 . . . . . . . . . . . . . . . . . . . $1,500,000 2006, 2007, and 2008 . . . . . . . . . . . . . . . $2,000,000 2009 . . . . . . . . . . . . . . . . . . . . . . . . . $3,500,000 2010 and 2011 . . . . . . . . . . . . . . . . . . . $5,000,000 2012 . . . . . . . . . . . . . . . . . . . . . . . . . $5,120,000 2013 . . . . . . . . . . . . . . . . . . . . . . . . . $5,250,000 2014 . . . . . . . . . . . . . . . . . . . . . . . . . $5,340,000 2015 . . . . . . . . . . . . . . . . . . . . . . . . . $5,430,000 2016 . . . . . . . . . . . . . . . . . . . . . . . . . $5,450,000 2017 . . . . . . . . . . . . . . . . . . . . . . . . . $5,490,000 2018 . . . . . . . . . . . . . . . . . . . . . . . . . $11,180,000 2019 . . . . . . . . . . . . . . . . . . . . . . . . . $11,400,000 2020 . . . . . . . . . . . . . . . . . . . . . . . . . $11,580,000 2021 . . . . . . . . . . . . . . . . . . . . . . . . . $11,700,000 2022 . . . . . . . . . . . . . . . . . . . . . . . . . $12,060,000 2023 . . . . . . . . . . . . . . . . . . . . . . . . . $12,920,000 2024 . . . . . . . . . . . . . . . . . . . . . . . . . $13,610,000 2025 . . . . . . . . . . . . . . . . . . . . . . . . . $13,990,000

In general, each annual increase can only be allocated to transfers made (or appreciation occurring) during or after the year of the increase.

Example. A donor made $1,750,000 in direct-skip GSTs through 2005, and allocated all $1,500,000 of the exemption to those transfers. In 2025, the donor makes a $2,000,000 taxable GST. The donor can allocate $2,000,000 of exemption to the 2025 transfer but cannot allocate the $10,490,000 of unused 2025 exemption to pre-2025 transfers. However, if in 2005, the donor made a $1,750,000 transfer to a trust that was not a direct skip, but from which GSTs could be made in the future, the donor could allocate the increased exemption to the trust, even though no additional transfers were made to the trust. See Regulations section 26.2642-4 for the redetermination of the applicable fraction when additional exemption is allocated to the trust.

Keep a record of your transfers and exemption allocations to make sure that any future increases are allocated correctly.

Enter on line 1 of Part 2 the maximum GST exemption you are allowed. This will not necessarily be the highest indexed amount if you made no GSTs during the year of the increase.

The donor can apply this exemption to inter vivos transfers (that is, transfers made during the donor’s life) on Form 709. The executor can apply the exemption on Form 706 to transfers taking effect at death. An allocation is irrevocable.

In the case of inter vivos direct skips, a portion of the donor’s unused exemption is automatically allocated to the transferred property unless the donor elects otherwise. To elect out of the automatic allocation of exemption, you must file Form 709 and attach a statement to it clearly describing the transaction and the extent to which the automatic allocation is not to apply. Reporting a direct skip on a timely filed Form 709 and paying the GST tax on the transfer will prevent an automatic allocation.

Line 5

Section 2632(c) provides an automatic allocation to indirect skips of any unused GST exemption. The unused exemption is allocated to indirect skips to the extent necessary to make the inclusion ratio zero for the property transferred. You may elect

Instructions for Form 709 (2025) 21

Table for Computing Gift Tax

Column A	Column B	Column C	Column D
Taxable amount over—	Taxable amount not over—	Tax on amount in column A	Rate of tax on excess over amount in column A
- - - - - $10,000 20,000 40,000 60,000 80,000 100,000 150,000 250,000 500,000 750,000 1,000,000	$10,000 20,000 40,000 60,000 80,000 100,000 150,000 250,000 500,000 750,000 1,000,000 - - - - -	- - - - - $1,800 3,800 8,200 13,000 18,200 23,800 38,800 70,800 155,800 248,300 345,800	18% 20% 22% 24% 26% 28% 30% 32% 34% 37% 39% 40%

out of this automatic allocation as explained in the instructions for Part 3.

Line 6

Enter the amount of GST exemption you are applying to transfers reported in Part 3 of Schedule A. You may also wish to allocate GST exemption to transfers not reported on this return, such as a late allocation.

Notice of Allocation. To allocate your exemption to such transfers, attach a statement to this Form 709 and entitle it “Notice of Allocation.” The notice must contain the following for each trust (or other transfer).

Clear identification of the trust, including the trust’s EIN, if known.
If this is a late allocation, the year the transfer was reported on Form 709.
The value of the trust assets at the effective date of the allocation.
The amount of your GST exemption allocated to each gift (or a statement that you are allocating exemption by means of a formula such as “an amount necessary to produce an inclusion ratio of zero”).
The inclusion ratio of the trust after the allocation.

Total the exemption allocations and enter this total on line 6.

Note: Where the property involved in such a transfer is subject to an ETIP, an allocation of the GST exemption at the time of the transfer will only become effective at the end of the ETIP. For details, see Transfers Subject to an Estate Tax Inclusion Period (ETIP) , earlier, and section 2642(f).

Part 3—Tax Computation You must enter in Part 3 every gift you listed in Part 1 of Schedule D.

Column (c)

You are not required to allocate your available exemption. You may allocate some, all, or none of your available exemption, as you wish, among the gifts listed in Part 3 of Schedule D. However, the total exemption claimed in column (c) may not exceed the amount you entered on line 3 of Part 2 of Schedule D.

Column (d)

Carry your computation to three decimal places (for example, “1.000”).