I am a US citizen and a permanent resident living in the US. My family resides in Iran. My father which is a non-resident alien is currently supporting me financially and lives in Iran.
Due to OFAC sanctions, funds (gifts for financial support) cannot be transferred directly from my father's bank account in Iran to my bank account in the US. The funds (gifts) have to be transferred via a third country and using bank accounts which do not belong to my father. For example, my father would ask friends residing in Europe to send me funds from their European bank accounts and in turn my father would deposit funds into their accounts in Iran. I have already spoken to OFAC officials - such transfers are permitted from their end.
1) Would these transfers qualify as "Gifts from Foreign Persons” and therefor not be subject to income tax? Would I need any documentation to prove that these transfers are “Gifts from Foreign Persons” and not income?
(as defined on your website: https://www.irs.gov/businesses/gifts-from-foreign-person)
2) I understand that if I receive more than $100,000 in a given tax year from an individual (or a collection of individuals which are related) I’d have to file the 3520 Form. My question is that if different individuals who are not related send me an amount less than $100,000 each - but I receive a total of over $100,000 in a given tax year from different individuals sending me funds on behalf of my father, would I have to file the 3520 Form with my father listed as the ‘indirect’ sender of the funds?