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Deductions & credits
IRC Section 529(c).2 says;
(2)Gift tax treatment of contributionsFor purposes of chapters 12 and 13—
(A)In generalAny contribution to a qualified tuition program on behalf of any designated beneficiary—
(i)
shall be treated as a completed gift to such beneficiary which is not a future interest in property, and
(ii)
shall not be treated as a qualified transfer under section 2503(e).
Thus contributions to the 529 plan by the NRA grand-parents are indeed gifts to the beneficiary. Therefore the reporting threshold of US$100,000 or more does trigger a reporting of form 3520 for and on-behalf of the minor beneficiary ( in your case ).
Now to your specific questions:
Page 1 -- check Box -- your are an individual
Line 1a thru 1h filled with the details of the 529 beneficiary
Part IV, line 54 ---, check the box YES; since the transfers dates and amounts were spread over the year, I would put the date when the final amount was received from each of the Grandparents ---- e.g. 10/22/2024 ----Grand Father ( NAME ) Cash gift to 529 Plan ---- 60,000.
Last Page -- sign and date ( Note you are filing for the child beneficiary ).
Is there more I can do for you ?
August 8, 2025
6:58 PM