pk
Level 15
Level 15

Deductions & credits

@flyday2022 , 

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 ?
 

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