Multiple Foreign Donors, One Tax Year: How to Report
3520file editorial
The structure
Form 3520 Part IV is designed to accommodate multiple donors. Each donor goes on a separate row of the relevant table:
- Line 54 — one row per foreign individual or foreign estate donor.
- Line 55 — one row per foreign corporation or foreign partnership donor.
You can list as many donors as the table accommodates. If you exceed the printed rows, you attach a continuation sheet that mirrors the table format.
A worked example with multiple donors
Asha is a US person in Chicago. During 2025, she received the following foreign gifts:
| # | Donor | Donor type | Country | Date | USD value | Notes |
|---|---|---|---|---|---|---|
| 1 | Pradeep Sharma (father, NRA) | Individual | India | March 5, 2025 | $60,000 | wedding gift |
| 2 | Lakshmi Sharma (mother, NRA) | Individual | India | March 5, 2025 | $40,000 | wedding gift |
| 3 | Ravi Sharma (uncle, NRA) | Individual | India | June 18, 2025 | $25,000 | birthday gift |
| 4 | Sharma Family Trading LLP | Partnership | UK | August 22, 2025 | $30,000 | corporate gift |
| 5 | Maria Garcia (friend, NRA) | Individual | Mexico | December 1, 2025 | $5,000 | Christmas |
Asha's aggregation analysis:
- Father + mother (spouses, both NRA): combined $100,000. Just on the borderline. Asha files out of caution.
- Uncle (NRA, but not aggregated with parents under standard reading): $25,000 standalone, below threshold.
- UK partnership: $30,000 > $17,339 threshold for partnerships — must report.
- Friend: $5,000 < $100,000 individual threshold — not reportable.
Total Form 3520 entries:
- Line 54, Row 1: Pradeep Sharma, March 5 2025, wedding gift cash, $60,000.
- Line 54, Row 2: Lakshmi Sharma, March 5 2025, wedding gift cash, $40,000.
- Line 54, Row 3: Ravi Sharma, June 18 2025, birthday gift cash, $25,000. (Even though uncle is below the $100,000 standalone threshold, conservative reporting includes all gifts from related foreign donors. The aggregation question is whether you must file at all; once you must file, reporting is comprehensive.)
- Line 55, Row 1: Sharma Family Trading LLP, UK, August 22 2025, corporate gift, $30,000.
The friend's $5,000 is below the threshold and unrelated to the other donors, so it does not appear on the form.
Ordering of donors
The form does not specify an order. We recommend:
- Chronological by date of gift (matches how the IRS reads the form).
- Within the same date, list largest amount first.
- Group same-donor multiple-distribution rows together when feasible.
Continuation sheets
If you have more donors than rows on the printed form (Line 54 typically has 4 rows printed, Line 55 typically has 3 rows), attach a continuation sheet. Mark it "Form 3520 Continuation — Line 54" or "Line 55" at the top, mirror the column headings, and continue the row numbering.
When multiple donors actually equal one donor
The aggregation rules in Form 3520 instructions specify that "related" donors are combined for purposes of the threshold test. But you still report each gift separately on the form — the aggregation is only for "do I have to file" purposes, not for how the form is filled out.
So in Asha's example above, the mother and father remain separate rows on Line 54 (different names, different SSN-equivalent details), even though their gifts aggregated for threshold purposes.
What our app generates
When you add multiple donors in the questionnaire, we generate one PDF row per donor on the right line (Line 54 or Line 55 based on donor type). Multiple transactions from the same donor in the same year get multiple rows (one per transaction date), or get rolled into one row at the donor level if you prefer — your choice in the review step.
The threshold check runs across all entered donors before generating the PDF, and we surface a warning if your facts seem to fall just below the threshold (e.g. $99,500 aggregated) so you can decide whether to add the cautious bonus row.
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.