Multiple foreign gifts: how does the $100,000 Form 3520 threshold work?

The direct answer

The $100,000 Form 3520 threshold is an annual total, not a per-transfer limit. For each tax year, you add up every gift and bequest you received from a nonresident alien individual or foreign estate, together with gifts from foreign persons related to them. If that combined amount is more than $100,000, you file Form 3520 Part IV.

That means many small transfers can add up to a reporting requirement, and splitting money between givers who are related to each other — or routing it through another relative acting for them — does not, by itself, keep you under the threshold.

The three counting rules

The IRS wording

The Form 3520 instructions say that 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 question is about the donors and their relationship to one another. The IRS-published proposed regulations on foreign-gift reporting (proposed §1.6039F-1(c)(2)(i)(B), in Internal Revenue Bulletin 2024-24) describe this aggregation using a related-person standard that refers to §1.643(i)-1(d)(9). The Form 3520 instructions also contain a separate definition of persons related to you; this guide does not treat that definition as a complete test of whether two donors are related to each other. If you are unsure whether particular relatives count as related for this rule, have it reviewed rather than assume their gifts are separate.

"Know, or have reason to know"

You are expected to combine gifts when you know the donors are related or acting for each other, or when the facts give you reason to know. The instructions illustrate this with a recipient who receives gifts from both a foreign corporation and a nonresident alien and knows the corporation is wholly owned by that individual — that knowledge matters for how the gifts are counted. Ignoring obvious family or ownership links does not help.

Worked examples (2025 tax year)

Example 1: Monthly support

Jia's parents in Shanghai send her $9,000 every month during 2025, for a total of $108,000. Jia knows her parents are related to each other, so their transfers are added together. Each transfer is modest, but the related total is more than $100,000. Jia files Form 3520 Part IV and, because every transfer was over $5,000, lists each one.

Example 2: Two parents, two accounts

Kevin's mother sends $60,000 from her account and his father sends $45,000 from a different account. Kevin knows his mother and father are related to each other, so the total is $105,000 and Part IV is required. Using separate accounts changes nothing.

Example 3: Two years

Amy receives $70,000 from her parents in November 2025 and another $70,000 in February 2026. Each year's related total is $70,000, so neither year crosses the threshold — as long as there are no other gifts from related foreign persons in those years.

Example 4: Through a relative

David's parents want to give him $150,000. They send $90,000 themselves and ask his aunt to send $60,000 of their money. His aunt is sending his parents' money for them — acting as their intermediary — so all $150,000 is counted together, and Part IV is required. Line 56 also asks whether you have reason to believe a donor was acting as a nominee or intermediary.

Example 5: Unrelated donors

Grace receives $80,000 from her parents and a $40,000 graduation gift from a family friend in Singapore who is not related to her parents and is acting on his own. The related totals are $80,000 and $40,000. Neither group is over $100,000, so these gifts do not require Part IV.

What is listed once you cross the threshold

• Line 54 (nonresident alien individuals and foreign estates): list each gift or bequest over $5,000 — the date, a description, and the fair market value.
• If no single gift was over $5,000, write "No gifts or bequests exceed $5,000" instead of listing them.
• Line 55 is a separate question for purported gifts from foreign corporations and foreign partnerships, which have a much lower annual threshold. See Form 3520: reporting large foreign gifts.
• Line 56 asks whether you have reason to believe any donor was acting as a nominee or intermediary.

Common mistakes

• Comparing each wire to $100,000 instead of adding the year's total
• Testing each giver separately when you know, or have reason to know, the givers are related to each other
• Forgetting gifts of property (jewelry, shares, a car) because no money was wired
• Leaving out a bequest from a parent's foreign estate in the same year as lifetime gifts — bequests are counted with gifts
• Counting tuition paid directly to your school, which is not a foreign gift (see tuition paid directly)
• Counting your own money moved from your own foreign account, which is not a gift at all

A simple tracking method

Keep one list for the year with these columns: date received, sender, sender's relationship to the other senders, purpose, amount in the foreign currency, exchange rate, amount in U.S. dollars. At year-end, group the senders who are related or acting for each other and total each group. If any group is over $100,000, you have your Form 3520 list ready.

When professional review makes sense

Ask a tax professional if money came through a company, a trust, or an unrelated person who may have been acting for your family; if you received property rather than cash; or if a total is close to $100,000 and you are not sure how to value or date a transfer.