Form 3520 — Foreign Gifts, Trusts & Inheritance Reporting

Accurate preparation of Form 3520 by a Washington-licensed CPA with cross-border tax experience. We help U.S. taxpayers report foreign gifts, inheritances, and foreign trust transactions correctly — and avoid the steep penalties that can come with late or incomplete filing.

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What Is Form 3520?

Form 3520, "Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts," is an information return that U.S. persons must file with the IRS to report certain transactions involving foreign trusts and the receipt of large gifts or bequests from foreign persons. It is not a tax return — no tax is calculated on the form itself — but it is a critical disclosure requirement with severe penalties for noncompliance.

Form 3520 covers four broad categories: (1) creation of or transfers to a foreign trust by a U.S. person, (2) distributions from a foreign trust to a U.S. beneficiary, (3) receipt of gifts or bequests from a non-resident alien individual or foreign estate exceeding $100,000, and (4) receipt of gifts from foreign corporations or partnerships exceeding certain thresholds. Each category is reported on a different part of the form, and the filing deadline and IRS submission address vary depending on which part applies.

Many taxpayers are unaware that receiving a large gift from a foreign relative triggers a U.S. reporting obligation — even though the gift itself is not taxable income. At TaxWise LLC, we help you determine whether a filing requirement exists, prepare the form accurately, and ensure it is filed on time. Our CPA has direct experience with cross-border tax matters, including U.S.-China family gift and trust structures, foreign inheritances from estate administrations abroad, and multi-jurisdictional reporting.

Who Needs to File Form 3520?

Recipients of Large Foreign Gifts

U.S. persons who receive gifts or bequests from a non-resident alien individual or foreign estate totaling more than $100,000 in a single tax year. This commonly affects immigrants and first-generation Americans receiving family support from abroad.

Foreign Inheritance Recipients

U.S. beneficiaries who inherit assets from a foreign estate. Even though the inheritance may not be subject to U.S. income tax, the receipt itself must generally be reported on Form 3520 if it exceeds the $100,000 threshold.

Foreign Trust Beneficiaries

U.S. persons who receive distributions from a foreign trust during the tax year. This includes direct distributions, loans from foreign trusts, and uncompensated use of trust property. Separate reporting applies to grantor vs. non-grantor trusts.

Foreign Trust Creators & Transferors

U.S. persons who create a foreign trust, transfer money or property to a foreign trust, or cause a trust to become a foreign trust. Even indirect transfers and constructive ownership situations may trigger a filing requirement.

Immigrants & Dual Citizens

New U.S. residents and dual citizens who maintain financial ties to their home country. Family gifts, dowries, wedding contributions, and help with a home down payment from foreign relatives are common triggers.

Prior-Year Non-Filers

Taxpayers who recently discovered they should have filed Form 3520 in a prior year. The IRS takes this omission seriously, but there are procedures — including reasonable cause statements and voluntary disclosure options — to bring past years into compliance.

When Form 3520 Filing Is Required

These real-world situations commonly trigger a Form 3520 filing obligation. If any of these apply to you, professional guidance is recommended.

You received a gift of more than $100,000 from your parents overseas

A common scenario for first-generation immigrants. Parents living abroad transfer funds for a home purchase, education, or family support. Even if no tax is owed, the report must be filed — and the threshold applies per foreign person, not per gift.

You inherited assets from a foreign relative's estate

Whether you inherited cash, real estate, or securities from a foreign estate, the total value received in a tax year above $100,000 is reportable. You may also have ongoing FBAR and Form 8938 obligations for the inherited foreign accounts.

You received a distribution from a foreign family trust

Many families abroad establish trusts for estate planning or wealth transfer. If you are a U.S. beneficiary and receive a distribution, the trust and the distribution are reportable. The trust itself may also need to file Form 3520-A if it has a U.S. owner.

You created a trust in your home country after moving to the U.S.

If you were involved in creating or funding a foreign trust while you were a U.S. person, you generally must report it on Form 3520 in the year of creation and in subsequent years for any activity. This is separate from the ongoing Form 3520-A obligation for the trust.

You received a large gift from a foreign corporation

Gifts from foreign corporations or partnerships exceeding certain annual thresholds ($17,339 for 2024) must also be reported. This can arise in family business structures where a foreign company makes distributions characterized as gifts.

You received multiple smaller gifts from the same foreign person

The thresholds are based on the aggregate of all gifts from a single foreign person during the tax year. Multiple transfers that individually are below the threshold but collectively exceed it must still be reported.

Documents to Gather for Form 3520

Having these documents helps us prepare your Form 3520 accurately. The specific documents needed depend on which part of the form applies to your situation.

Form 3520 vs. Form 3520-A

These two forms are often confused. Both relate to foreign trusts, but they serve different purposes and are filed by different parties.

Form 3520 Form 3520-A
Filed By U.S. person who receives gifts, inheritances, or trust distributions; or who creates/transfers to a foreign trust The foreign trust itself (if it has a U.S. owner)
Purpose Reports transactions with foreign trusts and receipt of large foreign gifts Annual information return of the foreign trust's income, deductions, and distributions
Due Date April 15 (or the 15th day of the 4th month after the trust's tax year end for trust-related parts), with extensions available March 15 (or the 15th day of the 3rd month after the trust's tax year end), with extensions available
Covers Foreign gifts, foreign inheritances, trust distributions, trust creation, trust transfers, and loans to/from foreign trusts The foreign trust's annual financial activity and the U.S. owner's share of trust income
Interaction A U.S. person who is the owner of a foreign trust must ensure the trust files Form 3520-A AND must also file their own Form 3520 reporting their ownership and any transactions. Both forms are generally required, not one or the other.

How We Help With Form 3520

1

Determine Your Filing Obligation

We review your specific situation — the type and amount of foreign gifts, inheritances, or trust transactions — and determine which parts of Form 3520 apply, whether Form 3520-A is also required, and what the filing deadline is. Not every foreign transaction triggers a requirement; we apply the thresholds and rules carefully to avoid unnecessary filings.

2

Gather Information & Prepare the Form

We tell you exactly what we need and help you assemble the documentation. We then prepare Form 3520 (and Form 3520-A, if applicable), ensuring all required schedules are complete and consistent with related filings such as your Form 1040, FBAR, and Form 8938.

3

File With the Correct IRS Office

Unlike most tax forms, Form 3520 is not filed with your tax return — it must be mailed to a specific IRS office depending on which part applies. We handle the mailing and ensure delivery tracking. The form cannot be e-filed.

4

Prior-Year Compliance & Reasonable Cause

If you missed a prior-year filing, we help you come into compliance. This may involve preparing the delinquent form with a reasonable cause statement explaining why the filing was late. Where appropriate, we discuss IRS voluntary disclosure options and the Delinquent International Information Return Submission procedures.

Common Mistakes to Avoid With Form 3520

These Errors Can Trigger Significant Penalties

  • Assuming foreign gifts are not reportable because they're not taxable — Form 3520 is an information return, not a tax return. The gift may not be taxable income, but you still generally must report it if it exceeds the threshold. Non-filing penalties apply regardless of whether tax was owed.
  • Filing Form 3520 with your tax return — Form 3520 is filed separately and mailed to a different IRS address (generally in Ogden, UT, for gift reporting or Memphis, TN, for trust-related filings, depending on the part). Attaching it to your 1040 does not satisfy the filing requirement.
  • Not aggregating multiple gifts from the same foreign person — The $100,000 threshold applies to the total of all gifts from one foreign person during the tax year. Five gifts of $25,000 from the same person total $125,000 and must be reported.
  • Confusing Form 3520 with FBAR or Form 8938 — These are separate obligations. Having a foreign bank account triggers FBAR/8938. Receiving a foreign gift triggers Form 3520. Many cross-border taxpayers need all three, but they serve different purposes and go to different agencies or IRS divisions.
  • Missing the filing deadline — Form 3520 is generally due April 15 (with a 6-month extension available for the trust-related parts). Late filing can trigger automatic penalties starting at 5% of the gift amount per month, up to 25%.
  • Treating a foreign trust loan as non-reportable — Loans from a foreign trust to a U.S. person, including below-market or informal loans, are generally treated as distributions and must be reported. The IRS looks through form to substance in these arrangements.

Frequently Asked Questions

What foreign gifts are reportable on Form 3520?
You generally must file Form 3520 if you receive gifts or bequests from a non-resident alien individual or foreign estate totaling more than $100,000 during the tax year. Gifts from foreign corporations and partnerships exceeding certain thresholds (generally $17,339 for 2024, adjusted annually) are also reportable. The $100,000 threshold applies to the aggregate of all gifts from the same foreign person or estate in a single tax year.
Is a foreign inheritance the same as a foreign gift for Form 3520?
For Form 3520 reporting purposes, foreign gifts and foreign bequests/inheritances are treated similarly. Both are reportable on Part IV of Form 3520 if the aggregate amount from a non-resident alien individual or foreign estate exceeds $100,000 in a single tax year. However, the U.S. recipient generally does not owe U.S. tax on the gift or inheritance itself — the reporting is informational. Note that inherited foreign assets may generate ongoing income that is taxable and may trigger separate reporting obligations (FBAR, Form 8938).
What if the person who gave me the gift isn't a U.S. person?
That is precisely when Form 3520 may be required. If the giver is a non-resident alien individual or a foreign estate, and the aggregate gifts exceed $100,000 in a tax year, you must report them. Gifts from U.S. persons are not reportable on Form 3520 regardless of amount. The giver's status — not the recipient's — determines whether the gift is from a foreign person. If you are a U.S. person receiving a gift from your foreign parents, for example, the $100,000 threshold applies.
What is the difference between Form 3520 and Form 3520-A?
Form 3520 (Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts) is filed by U.S. persons who receive foreign gifts, inheritances, or trust distributions, or who create or transfer property to a foreign trust. Form 3520-A (Annual Information Return of Foreign Trust with a U.S. Owner) is the separate annual information return filed by the foreign trust itself when it has a U.S. owner. If you are the U.S. owner of a foreign trust, the trust must file Form 3520-A, and you must also file Form 3520 to report the trust's activities and any distributions received.
What are the penalties for not filing Form 3520?
The penalties for failing to file Form 3520 or filing an incomplete or inaccurate form can be severe. For failure to report foreign gifts, the initial penalty is 5% of the gift amount per month, up to a maximum of 25%. For foreign trust-related violations, penalties can be 35% of the amount transferred or distributed, plus potential additional penalties. The IRS may also assert that the entire Form 3520 is not timely filed, which could lead to large assessments even when no tax is owed on the underlying transaction. Reasonable cause relief may be available in some circumstances.
Do I need to file Form 3520 if I already reported the income on my tax return?
Yes, in most cases. Form 3520 is a separate information reporting requirement — it does not replace income reporting on your Form 1040, and reporting income on your tax return does not satisfy the Form 3520 filing obligation. The two serve different purposes: your tax return reports taxable income, while Form 3520 discloses the receipt of large foreign gifts or transactions with foreign trusts. Both must generally be filed, and they are submitted to different IRS addresses.

Need Help With Form 3520?

Schedule a consultation with a CPA experienced in foreign gift, trust, and inheritance reporting. We'll determine your filing obligations and prepare your Form 3520 correctly.

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IRS Circular 230 Disclosure: Any tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of avoiding federal tax penalties or promoting, marketing, or recommending any transaction or matter addressed herein.

Important: Do not send sensitive personal information such as Social Security numbers or banking details through unsecured forms or email. Use our secure client portal for document uploads. The information on this page is for general informational purposes only and does not constitute professional tax advice. Every taxpayer's situation is unique — please consult with a CPA regarding your specific facts and circumstances.