Form 3520 Thresholds for 2025: Limits and a 2020–2026 Table

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If you received money or property from a foreign person during tax year 2025, determine whether the transfer is a reportable gift or bequest and whether the applicable Form 3520 Part IV threshold was exceeded. Thresholds do not resolve every Form 3520 obligation, particularly foreign-trust reporting. A missed required foreign-gift report can expose the recipient to a penalty of up to 25%, subject to applicable relief and processing rules.

This guide focuses on tax year 2025 and preserves a comparison of published thresholds for 2020–2026. It explains annual adjustments, aggregation and itemization. Use the figure for the year of receipt; the 2026 amount does not replace the 2025 threshold when reviewing a 2025 gift.

2025 Form 3520 Reporting Thresholds

Under IRC Section 6039F and the IRS Form 3520 instructions, U.S. persons generally report covered foreign gifts or bequests in Part IV when the relevant aggregate exceeds the amounts below. Apply the donor-category and related-person rules and any exceptions. Qualified tuition or medical payments made on a person’s behalf are excluded from this gift definition; foreign-trust distributions follow separate reporting rules.

Source of Foreign Gift	2025 Reporting Threshold
Nonresident alien individual or foreign estate	$100,000 under the standard IRS individual/estate reporting guidance
Foreign corporation or foreign partnership	$20,116 (adjusted annually for inflation)

The $100,000 individual/estate threshold comes from administrative guidance, including Notice 97-34, rather than a $100,000 amount written directly into section 6039F. The statute begins with a $10,000 amount subject to cost-of-living adjustment. The table uses the standard IRS reporting guidance and annual published corporate/partnership figures; the 2024 proposal is discussed separately below.

Itemization rule: After the applicable individual/estate aggregate exceeds $100,000, separately identify gifts or bequests exceeding $5,000. If none exceeds $5,000, the instructions require the applicable indication rather than omitting the filing. For the corporate/partnership category, report each contributing gift when the applicable aggregate threshold is exceeded.

Historical Threshold Table (2020–2026)

The published corporate/partnership reporting amount increased in each of the years shown. The individual/estate column reflects the standard $100,000 reporting guidance. Each revenue procedure supplies the corporate/partnership amount for its indicated tax year.

Tax Year	Foreign Individual / Estate Threshold	Foreign Corporation / Partnership Threshold	IRS Source
2020	$100,000	$16,649	Rev. Proc. 2019-44
2021	$100,000	$16,815	Rev. Proc. 2020-45
2022	$100,000	$17,339	Rev. Proc. 2021-45
2023	$100,000	$18,567	Rev. Proc. 2022-38
2024	$100,000	$19,570	Rev. Proc. 2023-34
2025	$100,000	$20,116	Rev. Proc. 2024-40
2026	$100,000	$20,573	Rev. Proc. 2025-32

The published corporate/partnership threshold rose from $16,649 for 2020 to $20,116 for 2025, an increase of approximately 20.8%. The full figures are preserved in the table.

How the Inflation Adjustment Works

Section 6039F(d) adjusts the statutory $10,000 starting amount through the cost-of-living rules referenced in section 1(f)(3), using a 1995 reference year. This is a statutory index calculation, not an assumed fixed percentage increase or a simple instruction to compare today’s C-CPI-U directly with 1995. Use the IRS’s published annual amount rather than estimating it.

You do not need to calculate this yourself — the IRS publishes the final figure each year. To find the threshold for any specific tax year:

1. Go to IRS.gov/InflationAdjustment
2. Select the applicable tax year news release
3. Click the Revenue Procedure link
4. Search for “Section 6039F” or “Notice of Large Gifts Received from Foreign Persons”

The change from $16,649 for 2020 to $20,116 for 2025 is $3,467, or approximately 20.8%. This calculation describes the published thresholds; it does not establish which particular years of inflation caused the change.

Related Parties Aggregation Rule

The aggregation rules differ by donor category. Related-person and nominee rules matter for individual/estate gifts. For purported gifts from corporations and partnerships, the standard IRS instructions require aggregation across those entities even when they are unrelated.

For foreign individuals and estates: Combine gifts or bequests from different nonresident alien individuals or foreign estates if you know or have reason to know they are related, or one acts as a nominee or intermediary for another. Apply the $100,000 threshold to the relevant aggregate.

For foreign corporations and partnerships: Aggregate purported gifts from all foreign corporations and foreign partnerships, together with gifts from foreign persons you know or have reason to know are related to those entities. The corporate and partnership donors do not have to be related to one another. For 2025, the applicable threshold is $20,116.

Example for 2025: You receive purported gifts of $8,000 from Foreign Corp A and $14,000 from Foreign Corp B, both subsidiaries of the same foreign parent. The $22,000 aggregate exceeds $20,116, so both must be reported. Under the standard IRS instructions the same aggregation result applies even if the two corporations are unrelated. The characterization of the payments must also be evaluated.

Review the relevant notices, filing history, records, and deadlines before choosing a response. Evaluate professional assistance according to the facts, applicable law, and agreed scope of representation. Related resources: IRS Foreign Filings practice page.

Edge Cases: When the Gift Straddles the Threshold

Partial-Year Gifts

For a calendar-year 2025 recipient, purported corporate gifts of $10,000 in November and $12,000 in December total $22,000 and exceed the $20,116 threshold. Both amounts enter the annual aggregate even though neither individually exceeds it. Other required related-person or entity amounts must also be considered.

Gifts Received in Multiple Years

Apply each tax year’s threshold to that year’s receipts: the 2024 corporate/partnership amount was $19,570, while the 2025 amount was $20,116. A missed 2024 filing is a separate issue that should be reviewed using its own due date, extensions, filing history and penalty rules. Do not assume it remains open indefinitely or that a penalty is automatically assessed; the statutory monthly rate, 25% cap, relief provisions and current processing policy must be considered.

Gifts From Foreign Corporations That Are Recharacterized

A payment labeled a gift by a foreign corporation or partnership can be recharacterized by the IRS under section 672(f)(4). Being below a Form 3520 reporting threshold does not itself make the receipt tax-free. Review the transaction’s substance and any income tax or separate reporting duties. Related resource: IRS audit representation.

Gifts That Push You Just Over the Threshold

When the relevant aggregate exceeds the threshold, follow the applicable itemization instructions. For individual/estate gifts, separately identify gifts or bequests exceeding $5,000; if none exceeds $5,000, indicate that as instructed. For the corporate/partnership category, individually report the contributing gifts. Merely equaling a threshold is not the same as exceeding it.

Penalties for Missing the Deadline

Under IRC Section 6039F(c), failure to report covered foreign gifts on time can lead to the following statutory consequences, subject to the applicable exception and procedures:

• Determine the income tax consequences of the unreported receipt from its facts; a genuine gift does not automatically become taxable income merely because a form was late
• Impose a penalty of 5% of the gift amount per month for each month the failure continues
• Cap total penalties at 25% of the total value of the unreported gift

The section 6039F reasonable-cause exception requires showing that the failure was due to reasonable cause and not willful neglect. Relief is fact-specific; the size of a gift alone does not establish or defeat the exception. Current IRS policy ended automatic assessment at filing for late-filed Part IV gift reports, but reporting duties and potential penalties remain. If a filing was missed, identify the proper response promptly; proactive disclosure or professional assistance does not guarantee a lower cost or penalty cancellation.

Frequently Asked Questions

Is the $100,000 threshold for individuals also inflation-adjusted?

The standard IRS instructions use $100,000 for qualifying gifts or bequests from nonresident alien individuals and foreign estates. That higher administrative threshold is not the corporate/partnership amount adjusted each year. The 2024 proposal described different inflation-adjustment provisions; do not mix selected proposed provisions with the standard instructions without satisfying the proposal’s reliance conditions.

Does a foreign inheritance count toward the threshold?

Qualifying bequests from nonresident alien individuals or foreign estates count toward the relevant $100,000 aggregate under the standard guidance. Apply related-person rules and any exceptions. A genuine inheritance is generally excluded from income, but income associated with inherited property, trust distributions and covered-expatriate gifts or bequests can involve separate tax or reporting rules. Form 3520 reporting is distinct from whether tax is due.

When is Form 3520 due?

For a calendar-year 2025 individual, Form 3520 is generally due April 15, 2026. A valid income tax filing extension can extend it to October 15, 2026; identify the extension on Form 3520. Certain U.S. citizens or residents living and working abroad, or serving abroad in the military, qualify for a June 15 deadline and must attach the required statement. In general the due date is the 15th day of the fourth month after the tax year, subject to applicable extensions and weekend or legal-holiday rules. Consult the filing instructions; Form 3520-A has different rules.

How do the 2024 proposed regulations address the individual threshold?

The May 8, 2024 proposal described a $100,000 individual/estate threshold with cost-of-living adjustment, rather than replacing it with the corporate threshold. Its reliance provision covered specified tax years ending after May 8, 2024 and beginning on or before final regulations are published, conditioned on the taxpayer and related persons applying the proposal in its entirety and consistently through the specified period. This is a description of that proposal, not a representation that every proposed rule is final or may be selected independently. Check the applicable law and current IRS instructions before relying on it.

I received a gift from a foreign corporation under the threshold — do I still need to do anything?

For 2025, aggregate purported gifts from all foreign corporations and foreign partnerships, together with gifts from foreign persons you know or have reason to know are related to those entities. If that aggregate does not exceed $20,116, Part IV reporting is not required for that category. Confirm the payment’s character and any separate reporting obligations; the IRS may recharacterize purported corporate or partnership gifts.

Get Help from an International Tax Attorney

Foreign-gift reporting requires checking the recipient’s and donor’s status, the tax year, the nature of the transfer, aggregation rules and exceptions. The corporate/partnership amount changes annually; do not assume every threshold in the article does. Penalties and available relief depend on the applicable rule and facts.

Review the relevant notices, filing history, records, and deadlines before choosing a response. Evaluate professional assistance according to the facts, applicable law, and agreed scope of representation. Related resources: penalty abatement.

If you own a foreign trust and need help with Form 3520-A filing obligations or penalty exposure, see our dedicated page: Foreign Trust Reporting Attorney for Forms 3520 and 3520-A.

Contact the firm to discuss the transfer, relevant records, notices and deadlines. Confirm the proposed representative’s qualifications, the scope of services, fees and any confidentiality limits before engaging counsel.