The direct answer
Probably yes, if you are a U.S. citizen or U.S. tax resident and the money was a gift (or inheritance) from parents who are nonresident aliens. When the gifts and bequests you receive during the tax year from a nonresident alien individual or a foreign estate, plus those from foreign persons related to them, total more than $100,000, you must file Form 3520, Part IV.
Two things are true at the same time:
- Tax: a true gift or inheritance is generally not taxable income to you, no matter how large.
- Reporting: a large foreign gift still has to be reported. Form 3520 is filed separately from your Form 1040, and the penalty for skipping it is based on the size of the gift.
| Your situation (2025 tax year) | Form 3520 Part IV? |
|---|---|
| Parents (nonresident aliens) gave $80,000 in total | No — not more than $100,000 |
| Parents gave $120,000 in total | Yes |
| Mother gave $60,000, father gave $50,000, and you know they are related to each other | Yes — gifts from related donors are added together ($110,000) |
| Parents are U.S. citizens living in Taiwan and gave $150,000 | No — not a gift from a foreign person |
| You were a nonresident alien all year | Generally no — Part IV is filed by U.S. persons |
Who this applies to
Three facts decide whether this rule is yours:
- You are a U.S. person. U.S. citizens and resident aliens (green card holders and people who meet the substantial presence test) file Part IV. See Am I a U.S. tax resident?
- The giver is a foreign person. For this threshold, that means a nonresident alien individual or a foreign estate. A parent who is a U.S. citizen or green card holder is not a foreign person, even if they live abroad.
- It is really a gift or bequest. A loan you must repay, payment for work, or a business distribution is not a gift and follows different rules.
How the $100,000 is counted
The threshold is not "per person" or "per transfer." You add together, for the tax year:
- every gift and bequest from the same nonresident alien or foreign estate, and
- gifts from other nonresident aliens and foreign estates that you know, or have reason to know, are related to that person — or that one is acting as a nominee or intermediary for another.
This is how the Form 3520 instructions put it: to calculate the $100,000 threshold, you aggregate gifts from different nonresident aliens and foreign estates if you know, or have reason to know, that those persons are related to each other or that one is acting as a nominee or intermediary for the other. The instructions' own example: $75,000 from one nonresident alien and $40,000 from a related nonresident alien total $115,000, so both gifts are reported. If you are not sure whether particular relatives count as related to each other for this rule, have it reviewed rather than assume their gifts are separate. For more on multiple transfers and donors, see Multiple foreign gifts: how does the $100,000 threshold work?
What does not count toward the $100,000
- Qualified tuition or medical payments made on your behalf — for example, tuition paid directly to your university. See My parents paid my tuition directly — do I report a foreign gift?
- Gifts from U.S. citizens or U.S. tax residents, even if they live abroad.
- Distributions from a foreign trust. These are reported in Part III of Form 3520, not Part IV. See Foreign gift from your parents vs. foreign trust distribution.
- Your own money moved from your own foreign account. That is not a gift at all. See I transferred my own money from overseas to the U.S. — is it taxable?
A worked example
Ming is a U.S. citizen living in California. His parents are Taiwanese citizens who live in Taipei and have never lived in the U.S. During 2025:
| Date | From | Purpose | Amount (USD) |
|---|---|---|---|
| March 2025 | Father | Help with living costs | $30,000 |
| July 2025 | Mother | Wedding gift | $50,000 |
| December 2025 | Father | Year-end gift | $25,000 |
| Related total | $105,000 |
Result: none of this is taxable income to Ming. Ming knows his mother and father are related to each other, so under the aggregation rule he adds their gifts together. His related total is more than $100,000, so he must file Form 3520 Part IV for 2025. On line 54 he lists each gift over $5,000 with the date, a description, and its fair market value in U.S. dollars. If his parents had stopped at $95,000, there would be nothing to file.
What filing looks like (high level)
- Form: Form 3520, page 1 identifying information and Part IV (line 54 for nonresident alien individuals and foreign estates).
- What to list: each gift or bequest over $5,000. If none of the individual gifts was over $5,000 but the total is over $100,000, you still answer "Yes" and write "No gifts or bequests exceed $5,000" instead of listing them.
- Not attached to your Form 1040. It is a separate filing. For 2025 gifts, it is due by the due date of your income tax return, including extensions, and it cannot be extended past October 15, 2026 for calendar-year filers.
The due dates, extension box, and mailing address are covered in Form 3520: reporting large foreign gifts.
Common misunderstandings
- "It's tax-free, so I don't need to report it." Not taxable and not reportable are different questions. A $300,000 gift can be tax-free and still require Form 3520.
- "My accountant files my 1040, so it's covered." Form 3520 is separate. Ask your preparer directly whether it is being filed.
- "Each parent gave under $100,000." Gifts from donors you know, or have reason to know, are related to each other are added together — they are not tested one donor at a time.
- "The money went into my U.S. account, so the IRS already knows." A bank receiving a wire is not the same as you filing Form 3520.
- "The gift itself is taxable because it is so large." Generally not. What becomes taxable is the income the money earns afterward — interest, dividends, rent, and gains.
If a reportable foreign gift is not reported on time, the penalty can be 5% of the gift for each month it goes unreported, up to 25%, unless the failure was due to reasonable cause and not willful neglect. The IRS may also decide the income tax treatment of the money itself. If a deadline has already passed, read I filed Form 3520 late — what should I do now?
Records to keep
- Wire confirmations or bank statements showing the date, amount, and sender of each transfer
- The exchange rate you used to convert each transfer into U.S. dollars
- A note, message, or letter from your parents showing the money was a gift (not a loan)
- Proof of your parents' status if relevant (for example, that they are not U.S. citizens or green card holders)
- A copy of the Form 3520 you filed and proof of mailing
When professional review makes sense
Get help from a CPA or tax attorney if the money might be a loan or payment rather than a gift, if any of it came from a family company or a trust, if a parent gave up U.S. citizenship or a green card, if the gift was property rather than cash, or if you missed an earlier year's Form 3520.