The rule

Use the exchange rate on the date you received the gift to convert the foreign-currency amount to USD. Not today's rate. Not the date of death. Not December 31. The date of receipt.

The IRS accepts two sources:

Treasury daily reporting rates of exchange (the "Treasury rates"), published by the Bureau of the Fiscal Service.
A reputable spot-rate provider — Bloomberg, Reuters, OANDA, OpenExchangeRates, your bank's settlement-date rate.

For a single date, the difference between sources is typically less than 0.5%. Pick one and use it consistently.

What "date of receipt" means

The IRS expects the date you had constructive control of the gift — not necessarily the date it left the donor's account.

Scenario	Date of receipt
Wire from foreign account to your US account	Date the funds posted to your US account
Cash gift handed to you in person	Date you accepted the cash
Foreign property transferred to your name	Date the title transferred
Foreign brokerage account renamed to you	Date the account was officially in your name
Bequest paid via foreign probate	Date the probate court ordered the distribution to you

A wire that left the foreign donor's account on March 5 and arrived in your US account on March 7 has a date of receipt of March 7. Use the March 7 exchange rate.

A worked example

Your aunt in Mumbai sent you ₹8,500,000 on April 3, 2025. The wire posted to your US account on April 4, 2025.

Date of receipt: April 4, 2025.
USD/INR exchange rate on April 4, 2025: assume 0.0118 USD per INR.
USD value of gift: 8,500,000 × 0.0118 = $100,300.

You report $100,300 on Form 3520 Part IV Line 54.

If you had used the year-end rate (December 31, 2025) instead, the rate might be 0.0115, and your USD value would be $97,750 — which would fall under the $100,000 threshold and incorrectly suggest you do not need to file. Using the wrong rate can change whether you file at all.

Multiple wires from the same donor

If your foreign donor sent multiple transactions on different dates, each transaction uses its own exchange rate. Do not average them. Do not aggregate then divide.

Example: Three wires from your foreign uncle in 2025 — ₹3,000,000 on January 15, ₹4,500,000 on June 20, ₹2,800,000 on November 30. Each uses the spot rate for its own receipt date:

Jan 15 wire at Jan 15 rate.
June 20 wire at June 20 rate.
Nov 30 wire at Nov 30 rate.

Sum the three USD values to get the donor's total gift amount.

Property gifts (non-cash)

If the gift is property (real estate, vehicles, jewelry, art, securities), report the fair market value in USD on the date of receipt. For most non-cash gifts you need a defensible valuation method:

Foreign real estate: independent appraisal, comparable-sale analysis, or in some cases the value declared in the foreign country's gift/inheritance tax filing.
Foreign brokerage account: the account's value on the transfer date, in foreign currency, converted to USD at the spot rate that day.
Foreign artwork or collectibles: independent appraisal.

The appraisal itself does not get attached to Form 3520, but you keep it in your records in case the IRS asks.

What if the rate isn't available

For obscure currencies or remote dates, a published Treasury rate may not exist. Fall back to:

The nearest published Treasury rate (closest date).
A commercial spot-rate provider's quote for the same date.
Your bank's settlement-date rate if the gift was a wire.

Use a single source for any given filing and document your choice.

Why historical rates matter

Year-end rates are easy to find and tempting to use. But they can move 10-15% in a single year. A €150,000 gift in March 2022 vs. December 2022 differs by about $20,000 in USD value depending on which date you pick.

Using the year-end rate when you should have used the spot rate can:

Take you over the threshold when you shouldn't be (filing when not required), or
Take you under the threshold when you should be over (failing to file when required, which is the penalty risk).

How our app handles it

When you enter a transaction with a foreign currency amount and a date, we automatically pull the closing spot rate for that date from OpenExchangeRates (the same source many CPA firms use). The USD value is locked on your filing. We store the rate, the source, and the timestamp of the lookup in the audit log so you can defend the conversion if questioned.

You can override the rate manually if you have a better source (e.g., your bank's actual settlement rate). The override is noted in the audit log.

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.

Currency Conversion on Form 3520: Which Exchange Rate?