Based on what I read on IRS, if a gift from a non-resident alien exceeds $100K, the recipient needs to report it on Form 3520. In my scenario, the combined amount of monetary gifts is above 100K, but each individual gift is below 100K, and the gifters are not related to each other. I wonder if I still need to report these gifts. Thanks!

1 Answer 1


Thank you to TTT for pointing out that I missed a detail in my source. A similar IRS page sheds some more light on the question:

You must aggregate gifts received from related parties. For example, if you receive $60,000 from nonresident alien A and $50,000 from nonresident alien B, and you know or have reason to know they are related, you must report the gifts because the total is more than $100,000.

Since the IRS specifically specifies that you must aggregate gifts from related parties but never specifies that you must do so for non-related parties I would argue that no, you would not need to file Form 3520.

  • 2
    I'm not convinced this answers the question since OP specified A and B are not related. In fact, based on the quote you provided, my interpretation would be the answer is No.
    – TTT
    Commented Jan 18, 2017 at 22:37
  • I agree with you. I was scanning pages too quickly and missed that detail. Thanks for pointing it out!
    – Nosrac
    Commented Jan 19, 2017 at 2:07

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