What Form 3520 is for
Form 3520, Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts, is an IRS information return. U.S. persons use it to report three kinds of things: certain transactions with foreign trusts, ownership of foreign trusts, and the receipt of certain large gifts or bequests from foreign persons.
This guide covers the part most families need: Part IV, for gifts and inheritances received from foreign persons. If you are dealing with a foreign trust, get professional help — those parts of the form are far more complex.
A gift from family abroad is generally not taxable income to you. Form 3520 exists so the IRS knows about large transfers from foreign persons. The cost of getting it wrong comes from penalties, not from tax on the gift itself. See Foreign gifts: is money from parents overseas taxable?
Who must file Part IV
You must complete Part IV if you are a U.S. person — a U.S. citizen or a U.S. tax resident (see Am I a U.S. tax resident?) — and during the tax year you received:
| From | Threshold for the year | Form 3520 line |
|---|---|---|
| Nonresident alien individuals or foreign estates (gifts or bequests) | More than $100,000 in total, including gifts from foreign persons related to them | Line 54 |
| Foreign corporations or foreign partnerships (purported gifts) | More than $20,116 for 2025 ($20,573 for 2026) | Line 55 |
The aggregation rule
To decide whether you passed $100,000, add together gifts from different nonresident aliens and foreign estates if you know — or have reason to know — that they are related to each other, or that one is acting for another. The IRS instructions give this example: a $75,000 gift from one nonresident alien and a $40,000 gift from a related nonresident alien total $115,000, so you must report both.
What is not a foreign gift
- Amounts paid on your behalf for qualified tuition or medical payments
- Gifts from U.S. citizens or U.S. tax residents
- Distributions from a foreign trust — these go in Part III, not Part IV (see Foreign gift from your parents vs. foreign trust distribution)
How to complete Part IV
| Line | What it asks | What to do |
|---|---|---|
| Line 54 | Did you receive more than $100,000 from nonresident aliens or foreign estates? | Check "Yes" and list each gift or bequest over $5,000: the date, a description, and its fair market value. If none was over $5,000, write "No gifts or bequests exceed $5,000" in column (b) of the first line. |
| Line 55 | Did you receive more than the section 6039F threshold from foreign corporations or partnerships? | Check "Yes" and list each gift and the donor's identity. The IRS may recharacterize these "gifts" as taxable income. |
| Line 56 | Was a foreign donor acting as a nominee or intermediary for someone else? | Check "Yes" if you have reason to believe so, and explain. |
You also complete the identifying information on page 1 (your name, address, and taxpayer identification number). Gifts are reported in U.S. dollars; keep a record of the exchange rate you used for transfers made in another currency.
When and where to file
| Your situation (calendar-year individual) | Form 3520 due for 2025 gifts | Form 3520 due for 2026 gifts |
|---|---|---|
| Standard | April 15, 2026 | April 15, 2027 |
| U.S. citizen or resident living and working outside the U.S. and Puerto Rico (or on military duty abroad) on the return due date | June 15, 2026 — attach a statement showing you qualify | June 15, 2027 — attach a statement showing you qualify |
| You extended your income tax return (Form 4868) | October 15, 2026 — check box 1k and enter the form number of the extended return | October 15, 2027 — check box 1k and enter the form number of the extended return |
Form 3520 is not attached to your Form 1040. Under the current instructions, mail it to:
Internal Revenue Service Center
P.O. Box 409101
Ogden, UT 84409
Only a complete Form 3520, including required attachments, is considered timely filed. If the due date falls on a weekend or legal holiday, file by the next business day.
Form 3520 cannot be extended past October 15 for calendar-year filers. U.S. citizens and residents abroad who get the extra discretionary extension of their income tax return to December 15 still must file Form 3520 by October 15.
Penalties
If you do not report a foreign gift on time, or the information is incomplete or incorrect:
- The penalty is 5% of the amount of the foreign gift for each month it is not reported, up to 25%.
- The IRS may determine the income tax consequences of the money — it may not accept that it was a gift.
- No penalty applies if you can show the failure was due to reasonable cause and not willful neglect.
Example: a $200,000 gift reported more than five months late could face a penalty of up to $50,000 (25%) — even though the gift itself was never taxable.
Get help from a CPA or tax attorney if your Form 3520 is late, if a "gift" came from a company or might be a loan or payment, if a foreign trust is involved, or if the giver was a former U.S. citizen or green card holder. Late filings should include a reasonable-cause explanation — see I filed Form 3520 late — what should I do now?