You will see me say “you” throughout this guide. I want you to feel like a trusted colleague is walking you through a checklist, not handing you a pile of tax jargon. I will flag 2025 updates, give you filing steps, share a practical records list, and offer a short reasonable‑cause template you can adapt if you are filing late. If you run a CPA firm or family office, there is a quick section on workflow controls so your team can prep Form 3520 cleanly and protect review time.
Key Takeaways
- Form 3520 is an informational return. You use it to report foreign trust activity and large foreign gifts or bequests. It does not compute a tax by itself, although penalties apply if you do not file when required.
- For gifts from foreign individuals or foreign estates, reporting starts when the total from that donor group crosses 100,000 in a tax year. For gifts from foreign corporations or partnerships, the inflation‑adjusted threshold for 2025 is 20,116.
- You mail Form 3520 as a stand‑alone filing to IRS Ogden, not with your Form 1040. The IRS lists the current address as P.O. Box 409101, Ogden, UT 84409.
- Due dates align with your tax year. For most calendar‑year individuals, the due date matches your tax return’s normal deadline, with June 15 available if you qualify for the automatic foreign extension, and October 15 if you have a valid extension.
- If you missed a deadline, file as soon as possible, include a detailed reasonable‑cause statement, and keep strong records of wires, appraisals, trust papers, and correspondence.
What Form 3520 Is, In Plain English
Form 3520 is how you tell the IRS about two buckets of cross‑border activity.
- Foreign gifts and inheritances that cross the applicable thresholds.
- Foreign trust activity, which includes creating or transferring assets to a foreign trust, being treated as the owner of a foreign trust, or receiving distributions, loans, or other benefits from it.
Think of it as a disclosure snapshot. You report dates, descriptions, fair market values, and who was involved. If you have foreign trust ownership, you also coordinate with the trust’s annual information filing on Form 3520‑A or attach a substitute if the trust did not file.
Bottom line, you are telling the IRS what moved, when it moved, and who the parties were. The form is independent from your income tax return, and you mail it to Ogden.
Who Must File Form 3520
You are on the hook to file if you are a U.S. person and any of the following happens during your tax year.
- You received more than 100,000 in aggregate gifts or bequests from a nonresident alien individual or foreign estate. Aggregation applies to related donors.
- You received more than the section 6039F threshold from a foreign corporation or foreign partnership. The threshold is inflation‑adjusted and equals 20,116 for taxable years beginning in 2025.
- You created or transferred assets to a foreign trust, are treated as an owner under the grantor rules, or received distributions, loans, or uncompensated use of trust property.
Executors may need to file for a decedent or an estate if there was foreign trust ownership or reportable transfers. Non‑U.S. persons generally do not file. When in doubt, check the Instructions’ “Who Must File” section and compare your facts.
Two Quick Reality Checks
- Gifts from foreign trusts are not reported as “gifts.” They are treated as trust distributions and go in the trust section of the form.
- If the foreign trust does not furnish Form 3520‑A, attach a substitute 3520‑A to your Form 3520 by your Form 3520 due date to avoid the owner penalty.
2025 What Changed, At A Glance
- The inflation‑adjusted threshold for gifts from foreign corporations or partnerships is 20,116 for taxable years beginning in 2025. The 100,000 threshold for foreign individuals and estates remains the same.
- The Instructions for Form 3520 carry a 12/2025 update with clarified timing language, the Ogden mailing address, and cross‑references to Form 3520‑A and penalties. Page shows last review on December 1, 2025.
Note, thresholds change. Always check the current IRS Instructions and the annual inflation revenue procedure before you file. I link to both in citations so you can verify the numbers that apply to your tax year.
Foreign Gifts And Inheritances, Explained
If you receive money or property from abroad, start with the donor type and the calendar‑year totals. That tells you whether Part IV is required.
- Foreign individual or foreign estate, file when your yearly total from that donor group exceeds 100,000. Aggregation applies to related persons.
- Foreign corporation or foreign partnership, file when your yearly total exceeds the inflation‑adjusted 6039F amount for your tax year, which is 20,116 for 2025. Aggregation applies to related entities.
Thresholds Table For 2025
| Donor type | 2025 threshold | How to aggregate | Where to report |
| Foreign individual | 100,000 | Aggregate by donor and related donors | Part IV, Line 54 |
| Foreign estate | 100,000 | Aggregate by estate and related donors | Part IV, Line 54 |
| Foreign corporation | 20,116 | Aggregate by entity and related persons | Part IV, Line 55 |
| Foreign partnership | 20,116 | Aggregate by entity and related persons | Part IV, Line 55 |
The 20,116 amount comes from the IRS annual inflation procedure for taxable years beginning in 2025, under section 6039F. The 100,000 figure stems from IRS guidance and remains the marker for individuals and estates. Always tie your filing to the instructions for your year.
What You Enter In Part IV
- Column (a), the date you received each gift or bequest.
- Column (b), a concise description, for example, cash wire, brokerage transfer, or residential property.
- Column (c), the fair market value on the date of receipt. Use bank records, statements, or an appraisal if needed, then keep that evidence with your files.
If you answered Yes to the 100,000 question but no single item exceeds 5,000, you note that fact rather than listing each item. The Instructions cover this in plain terms with examples.
Pro tip, if a foreign company sent funds that you believe are a true gift, confirm ownership ties. If the company is related to an individual donor, you may hit the lower corporate threshold sooner than you expect.
Simple Scenario You Can Model
You receive three wires from a foreign uncle, 60,000 in March, 30,000 in June, and 20,000 in December. Your total from that individual exceeds 100,000 for the year, so you complete Part IV and list each transfer with the date, description, and fair market value.
Now imagine a 25,000 transfer from a foreign corporation your uncle owns. That single payment crosses the 20,116 corporate threshold for 2025, so you also check the corporate question and list that item. The transfers may feel similar to you, but they trigger two different threshold rules.
Reporting Foreign Trust Transactions, Without The Headache
If your activity involves a foreign trust, Form 3520 uses Parts I through III.
- Part I, transfers to a foreign trust. Report what you moved, when you moved it, fair market value, and basis. If you exchanged property for a qualified obligation, include the terms.
- Part II, ownership. If you are treated as the owner under the grantor rules, identify the trust, the country, and the Code section that makes you the owner. If the trust did not provide Form 3520‑A, attach a substitute Form 3520‑A to your Form 3520 by your due date.
- Part III, distributions, loans, and benefits. Include direct and indirect benefits like a rent‑free stay in trust property or an interest‑free loan. List dates, descriptions, and fair market values, and include loan terms where relevant.
Penalties for trust‑related nonfiling can be significant, including percentage‑based amounts tied to the value of trust assets or distributions. The Instructions outline these sections and the continuation penalty rules if you do not file after IRS notice.
If you manage filings for clients, set a recurring calendar task two months before year end to confirm whether the trust will furnish Form 3520‑A. If not, build time to prepare and attach a substitute with the owner’s Form 3520. It protects your client from an avoidable penalty.
Deadlines, Extensions, And Where To Mail
For calendar‑year individuals, Form 3520 is due on the 15th day of the fourth month after year end. That aligns with April 15 in most years. If you qualify for the automatic two‑month foreign extension, your due date becomes June 15. If you file a valid return extension, your Form 3520 due date moves to the 15th day of the tenth month after year end, generally October 15.
You mail Form 3520 as a stand‑alone filing to:
- Internal Revenue Service Center
- P.O. Box 409101
- Ogden, UT 84409
The IRS Instructions direct filers to mail to Ogden. There is no IRS e‑file program for Form 3520 at this time, and tax press continues to confirm that the form is mailed as a stand‑alone return. Keep proof of mailing.
Amended Filings
If you discover an error, write AMENDED at the top of page one and mail a corrected form to the same Ogden address. Include any missing schedules and a brief explanation. The sooner you correct, the better your reasonable‑cause posture.
Step‑By‑Step, How To Complete Part IV For Gifts
- Confirm thresholds
- Test your total by donor type. Individuals and estates, look for 100,000 or more. Corporations and partnerships, compare to the inflation‑adjusted 6039F number for your tax year, 20,116 for 2025.
- List each item
- Column (a), the date received.
- Column (b), a brief description such as cash wire, ordinary shares, or a parcel address.
- Column (c), fair market value on the transfer date, supported by bank records or an appraisal.
- Aggregate by donor
- Sum by donor and related donors for individuals and estates. Sum by entity and related persons for corporations and partnerships.
- Keep your backup
- Do not attach bank statements or appraisals. Keep them for at least three years with your tax records. If you are late, you will need this support for reasonable cause.
Your Filing Checklist
- Identification page complete and accurate.
- Correct tax year checked.
- Part I, II, or III completed if you had foreign trust activity.
- Part IV completed if you crossed a gift threshold.
- Substitute Form 3520‑A attached if applicable.
- Signed and dated.
- Mailed to the Ogden address with tracking, and proof retained.
Penalties, Reasonable Cause, And Documentation That Wins
Penalties can be the greater of 10,000 or a percentage of the unreported amount, and trust‑related penalties can reach 5 percent of the value of trust assets treated as owned, with continuation penalties after IRS notice. The precise amounts depend on the part and the Code section. The Instructions outline the penalty framework and references.
When you are late, speed and documentation matter. File the form, attach a clear reasonable‑cause statement, and include facts that show ordinary business care and prudence. Keep copies of wires, trust documents, correspondence with advisors, and any appraisals. If a foreign trust failed to file Form 3520‑A, attach a substitute with your owner filing.
Reasonable cause comes from your facts, not magic words. Show what you did to comply, when you learned of the requirement, and how you fixed it promptly.
Short Reasonable‑Cause Template You Can Adapt
To the IRS Examiner, I respectfully request penalty relief for a late Form 3520 for tax year [Year]. I am a U.S. person who received [describe gift or trust distribution] on [dates]. I reasonably believed no filing was required because [brief explanation tied to facts or reliance on advisor]. I discovered the requirement on [date], prepared Form 3520 promptly, and am filing now with complete information. I have enclosed a timeline, bank confirmations, and correspondence showing my diligence. I have implemented a process to review cross‑border transfers monthly and to consult a qualified tax professional before year end. I acted with ordinary business care and prudence and request abatement based on reasonable cause.
Records To Keep, So Reviews Are Faster
Great records make Form 3520 straightforward and protect you if questions come up later.
- Gift letters or emails from the donor that clarify intent.
- Wire confirmations and bank statements showing the date and amount received.
- Appraisals or valuation memos for non‑cash property.
- Trust agreement, trustee statements, and beneficiary statements, if any.
- Any correspondence with advisors that shows your efforts to comply.
If You Work At A Firm, A Simple Workflow That Protects Review Time
From our experience building controlled delivery for accounting teams, Form 3520 files review much faster when you standardize three things.
- A single SOP for gifts and inheritances, with a one‑page intake that tags donor type, related parties, and threshold status.
- A naming convention for workpapers, for example, 3520_FilerName_Year_DonorType_DDMMMYY.
- A pre‑review checklist that confirms totals by donor type, substitutes any missing 3520‑A, and confirms the Ogden address on the cover letter.
Accountably focuses on review protection and workpaper structure for CPA and EA firms that want predictable delivery. If you manage seasonal surges or complex multi‑entity work, a disciplined SOP and layered review can save partners hours per file. Use your systems and templates. Our note here is purely about process control, not a sales pitch.
Frequently Asked Questions
Who is required to file Form 3520
You file if you are a U.S. person who crossed the thresholds for foreign gifts or who engaged in foreign trust activity, such as transfers, ownership, distributions, loans, or use of trust property. Executors may need to file for a decedent or an estate.
What is the foreign gift limit for Form 3520 in 2025
For foreign individuals and estates, the trigger remains 100,000 in a tax year. For foreign corporations and partnerships, the inflation‑adjusted threshold for taxable years beginning in 2025 is 20,116. Aggregation rules apply to related donors and entities.
Can I receive 100,000 from a foreign relative without reporting it
No. Once your aggregate gifts from a foreign individual or estate hit 100,000 for the year, you must report in Part IV. The filing is informational, and you should maintain strong records of the transfers and valuations.
Where do I mail Form 3520 and can I e‑file it
You mail Form 3520 to the IRS Service Center in Ogden, P.O. Box 409101, Ogden, UT 84409. The form is a stand‑alone information return mailed to the IRS, not filed with your Form 1040. There is no IRS e‑file program for Form 3520 at this time. Keep proof of mailing.
What if the foreign trust did not provide Form 3520‑A
Attach a substitute Form 3520‑A to your Form 3520 by your Form 3520 due date. Include owner and beneficiary statements. This step helps you avoid the owner penalty.
Are gifts from a foreign trust reported as gifts on Part IV
No. Amounts you receive from a foreign trust are reported as trust distributions on Part III, not as gifts. The IRS separates genuine third‑party gifts from trust distributions.
Practical Examples You Can Reuse
Cash gift from a foreign individual
You receive 120,000 total from a foreign parent across three transfers. You file Part IV, list each date and amount, and keep wire proofs and a simple note from your parent confirming intent to gift. You do not owe a tax on the gift, but you do owe a complete, on‑time form.
Payment from a foreign company labeled as a gift
A foreign company wires you 25,000. That exceeds the 20,116 2025 threshold for entities, so you answer Yes to the corporate question and list the transfer. If the company is related to a foreign individual who also gifted you funds, remember the related‑party aggregation rules.
Foreign trust distribution and an interest‑free loan
You stay in a trust‑owned vacation home for a week and later receive an interest‑free loan. Both count as benefits. Report the benefit and the loan terms in Part III with fair market values, then retain any trustee statements that support your entries.
Compliance Notes, So You Stay Current
- Always check the current Instructions for Form 3520 before you file. The IRS updated the page on December 1, 2025 and points you to the annual inflation procedure for the 6039F threshold.
- For your 2025 filing, the entity‑gift threshold is 20,116. For later years, find the current number in the IRS revenue procedure under “Notice of Large Gifts Received from Foreign Persons.”
- The Ogden mailing address is current as of October 28, 2025 on the IRS Where‑to‑File page. Check again if you are reading this much later.
If You Run A Firm, Keep Delivery Predictable
I have watched partners lose evenings to incomplete 3520 files. A little discipline fixes that.
- Intake on day one, capture donor type, related party ties, and threshold status.
- Name files consistently and version them once, not three times.
- Lock a three‑layer review, preparer, senior, final, with a short checklist that forces threshold math and confirms the Ogden address.
- Train staff to pull the correct inflation revenue procedure each fall and to cite it in a margin note.
Accountably works with CPA and EA firms that want offshore capacity without chaos. Our teams work inside your systems and templates, follow your SOPs, and protect review time with structured workpapers and defined SLAs. If you need seasonal lift or a dedicated team, keep it practical and controlled.