The exact rule

You must file Form 3520 Part IV if you are a US person who received more than $100,000 during the tax year in gifts or bequests from a nonresident alien individual or a foreign estate, in any combination.

"More than $100,000" means the threshold itself is not the trigger — $100,000 exactly does not require filing, but $100,000.01 does. Most filers err on the side of filing when in doubt.

What counts

Cash. Wire transfers, ACH, checks, Western Union, all of it.
Property at fair market value. Real estate, vehicles, jewelry, art — the USD value at the time of receipt.
Securities at fair market value. Foreign stock, bonds, mutual funds transferred to your account.
Inheritances. A bequest from a foreign decedent counts as a gift for Form 3520 purposes, regardless of probate timing.
Forgiveness of debt. If a foreign relative loaned you money and then said "forget about it," the forgiven balance counts as a gift in the year of forgiveness.
Below-market loans. If you got a loan from a foreign relative at an interest rate below the IRS applicable federal rate (AFR), the difference might constitute a gift.

What does NOT count

Gifts from US citizens or residents — even if the money came from overseas accounts. The donor's status as a US person is what matters.
Loans you actually have to repay. A bona-fide loan from a foreign relative, documented with a promissory note at a market interest rate, is not a gift. You should keep the documentation.
Tuition or medical payments made directly to an institution. If your foreign grandparent paid your university directly (not to you), that payment is excluded from Form 3520 under IRC § 2503(e) — but the exclusion only applies if the payment is made directly to the institution.
Reimbursement for expenses you incurred on the donor's behalf. If you bought something for your foreign uncle and he paid you back, that is reimbursement, not a gift.
Joint property under genuine joint ownership. If a foreign parent named you as a joint owner of an account decades ago and you withdraw your share, that is generally not a "gift" — it was already partly yours.

The aggregation rule

The $100,000 threshold is aggregated across all related donors in the same tax year. The "related" rules track family attribution:

Your foreign-resident parents are related to each other for this purpose.
Your foreign-resident grandparents are related to each other.
Your foreign-resident siblings are NOT related to your foreign-resident parents for aggregation purposes (controversial, but this is the standard reading).
Two foreign-resident cousins from opposite sides of the family are NOT related.

When in doubt, aggregate and disclose — over-disclosure is not penalized.

The corporation/partnership track

There is a parallel track for gifts from foreign corporations and foreign partnerships, with a much lower threshold — $17,339 for 2024, adjusted annually for inflation. If you received more than that from a foreign corporation or foreign partnership (or aggregated combination thereof), you file Form 3520 Part IV Line 55.

This catches situations like:

Distributions from a foreign LLC that elected to be classified as a partnership.
"Bonuses" from a foreign-based employer paid as a corporate gift.
Disguised dividends from a closely-held foreign corporation that is not paying you fair-market wages.

A worked example

Maria is a US citizen in Boston. During 2024:

Her foreign-resident mother wired her $40,000 in March.
Her foreign-resident father wired her $35,000 in June.
Her foreign-resident grandmother (her father's mother) wired her $30,000 in October.

Maria's individual aggregations:

Mother + father combined: $75,000 (related — they are married).
Grandmother: $30,000 alone.

Maria's analysis depends on whether grandmother aggregates with the parents. Conservative reading: aggregate all related-by-blood-or-marriage to maximum extent. $75,000 + $30,000 = $105,000 → file. Aggressive reading: parent-unit and grandparent-unit are separate. $75,000 alone < $100,000, $30,000 alone < $100,000 → do not file. The conservative reading is safer and what we recommend.

Why the threshold is set where it is

The $100,000 number has been fixed since the late 1990s without inflation adjustment. In real terms it has gotten significantly tighter over time. Compare to the FATCA Form 8938 threshold, which is indexed to filer status and presence. Congress could change the $100,000 threshold in any tax bill, but as of writing it stands at $100,000.

3520file is software, not a CPA firm or law firm. We prepare IRS Form 3520 based on the facts you provide. For advice on your specific situation, talk to a tax attorney or CPA. The above is plain-English explanation, not tax advice.

The $100,000 Foreign Gift Threshold in 2026: What Counts and What Doesn't