The pattern

You receive a foreign gift (or inheritance) above $100,000. The money goes into a foreign bank account in your name — typically because the donor cannot directly wire to your US bank, or because settling the foreign estate takes time, or because you maintain a foreign account already.

The foreign account balance, even temporarily, exceeds $10,000.

You now have a double filing:

Form 3520 — reports the receipt of the foreign gift/inheritance.
FBAR (FinCEN 114) — reports the foreign account that held the money.

Both for the same tax year. Both with the same deadline (April 15, both with October 15 extension). Different filing channels.

Why both apply

Form 3520 is about the event of receiving foreign money over the threshold. It does not matter where the money sat — what matters is that you received it.
FBAR is about the fact of having signature or financial-interest authority over a foreign financial account. It does not matter where the money came from or whether it was a gift — what matters is the account balance.

Different triggers, both can fire simultaneously.

Filing both — the exact steps

File Form 3520 — paper, signed in pen, mailed certified to:

Internal Revenue Service Center P.O. Box 409101 Ogden, UT 84409
File FBAR — electronically at https://bsaefiling.fincen.treas.gov. You submit a separate filing per US person (joint accounts with a spouse who is also a US person can file a joint FBAR via FinCEN Form 114a). Each foreign account gets its own entry.
Match the data between the two forms. Use the same currency conversion methodology (Treasury daily rates or the recipient's bank's settlement-date rate). Use the same dates. The IRS cross-references the two filings under FATCA-fed analytics, and inconsistency is a flag.

Common error: double-counting

People sometimes get confused and report the inherited money on both forms as if it were two different transactions. It is not. It is one event reported two ways:

Form 3520 reports the receipt as a gift/bequest at fair market value on the date of receipt.
FBAR reports the maximum account balance during the year, which may include the inherited money plus any other balance changes.

Example: Inherit $500,000 from a foreign aunt. Money sits in a foreign account for three months at $500,000. Then $400,000 wires to US, leaving $100,000 in the foreign account for the rest of the year.

Form 3520: reports $500,000 receipt on the date the inheritance was credited.
FBAR: reports maximum balance during year, which is $500,000.

The $500,000 is not double-counted — it is the same event reported from two different angles.

Currency conversion across the two forms

Form 3520 uses the spot rate on the date of receipt. FBAR uses the Treasury End-of-Year Exchange Rate (published by the Treasury Reporting Rates of Exchange) for converting the maximum-balance figure to USD.

These are different rates for different purposes, so the USD amounts on the two forms may not match exactly. That is expected and not a problem.

What if you also need Form 8938

The triple-filing case: Form 3520 + FBAR + Form 8938. Triggered when:

You received a foreign gift/inheritance over $100,000 → Form 3520.
The money sat in a foreign account at >$10,000 during the year → FBAR.
Your aggregate specified-foreign-financial-asset balance at year-end exceeded your filing-status threshold → Form 8938 attached to your 1040.

This is common for US persons who inherit and keep some foreign exposure (e.g., a foreign brokerage account they inherited remains open).

Penalties stack

Failure to file each is penalized separately:

Missing Form 3520: up to 25% of the gift amount.
Missing FBAR: $16,536 per account per year (non-willful 2024 rate).
Missing Form 8938: $10,000 initial + up to $50,000 if continued failure.

On a $500,000 inheritance held in one foreign account, the maximum theoretical penalty for missing all three filings is:

Form 3520: $125,000 (25% of $500K)
FBAR: $16,536 (one account)
Form 8938: $10,000-$60,000

Combined ceiling well over $150,000 for a single forgotten filing year. Compare to the actual cost of filing all three: about $130 ($99 for Form 3520 via us, $29 for FBAR via fbarfile.com, Form 8938 included in standard tax software).

Our cross-form check

When you complete the questionnaire, we ask:

"Did the gift go into a foreign bank or brokerage account in your name?"
"What was the maximum balance in that account during the year?"
"What was the balance at December 31?"

Based on your answers we flag FBAR and Form 8938 if they apply, and link to fbarfile.com for the FBAR side. We do not file FBAR — that has its own separate workflow at FinCEN — but we surface the obligation clearly so you do not miss it.

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.

When You Need to File Form 3520 AND FBAR