She should file a return because her unearned income is more than $1100. She doesn't have a tax liability, so there is no penalty, but she still has a filing requirement. Even if you're a dependent, you'll generally need to file your own 2020 tax return if:
- Your earned income (money you made by working) exceeds $12,400
- Your unearned income (interest, dividends, capital gains, etc.) exceeds $1,100
- Your business or self-employment net income (gross minus expenses) is at least $400
- Your gross income (earned plus unearned) exceeds the larger of $1,100 or your earned income (up to $12,050) plus $350
You can use the IRS Free File via TurboTax for her return, it will be free no matter when you file it. Create her own account for her return. You have to use the link in the help article to start a return there instead of TurboTax.
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