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The trustee of a foreign grantor trust with a US owner must file Form 3520-A, Annual Information Return of Foreign Trust With a US Owner, with the IRS each year.
The gift is from a foreign person and exceeds $100,000, so it is reportable on Form 3520. It does not matter if the gift was a single transactions, or 10 transactions of $90,000 (in the same year).
Anyone who receives a gift or bequest worth more than $100,000 (as adjusted for inflation) from someone who isnt a citizen or resident of the United States must file Form 3520 with the IRS by April 15th of the following year.
Reasonable cause is determined on a case by case basis considering all the facts and circumstances of your situation. Reasons that qualify for relief due to reasonable cause depend on the type of penalty you owe and the laws in the Internal Revenue Code (IRC) for each penalty.
U.S. persons (and executors of estates of U.S. decedents) file Form 3520 to report: Certain transactions with foreign trusts. Ownership of foreign trusts under the rules of sections Internal Revenue Code 671 through 679. Receipt of certain large gifts or bequests from certain foreign persons.
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Form 3520-A is the annual information return of a foreign trust with at least one U.S. owner. The form provides information about the foreign trust, its U.S. beneficiaries, and any U.S. person who is treated as an owner of any portion of the foreign trust under the grantor trust rules (sections 671 through 679).
A U.S. person must file Form 3520 if that person receives as a gift during the tax year either of the following: More than $100,000 from a nonresident alien individual or a foreign estate. More than a threshold amount from a foreign corporation or foreign partnership ($17,339 for gifts made in tax year 2022)

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