Form 3520 Part IV, line 54 (c). If several gifts are below $5k, where would I enter the total gift received?

[Diegos]

Received more than 100k from non US parent, some gifts are higher and some are lower than $5k. If the table in 54 (a), (b), (c) is only for gifts above $5k, the total FMV in (c) will not include the all gifts. Correct? Should I enter the total amount received somewhere?  Gifts: different securities, on different dates. 

[JotikaT2]

That is correct.  Part IV is required to be completed when any gift from a nonresident aggregates over $100,000 during the tax year, then only the gifts exceeding the $5,000 threshold get reported.  This does mean that the amounts listed in part IV may not match the aggregate overall amounts received in the event you received gifts below the $5,000 threshold.  These amounts would not be reported anywhere else per the instructions for Form 3520.  

[Diegos]

Excellent. Thank you! I do have a follow up question based on other discussions I read, where some recommend to “aggregate” but do not mentioned how that impact the Total gift disclosed. 

Let's say I received 4 securities:

1/1/23 Apple Stock FMV $2k

2/2/23 AMEX Stock FMV $100k

6/6/23 Vanguard Mutual Fund VTSAX $10k

7/7/23 Fidelity Mutual Fund FXAIX $4k

  Total Gift $116k

Question: Table in line 54 should be “Aggregate” or "Detail"?

Option "Aggregate":

Various Dates (a) / Stocks (b) / $102k (c)

Various Dates (a) / Mutual Funds (b) / $14k (c)

Total $116k

Option “Detail”:

2/2/23 AMEX Stock $100k

6/6/23 Vanguard Mutual Fund VTSAX $10k

Total $110k

The "aggregate" option Total would be $6k higher than "Detail"

[JotikaT2]

The detail option would be the correct method for reporting the amounts requested in the details for line 54.

You would check the yes box to the question asking if you received more than $100,000 during the year.  However, in the table, you would only enter those gifts that exceeded the $5,000 reporting threshold.  It is possible the overall gift amount will not match the gifts reported in the total box on line 54.

The following screenshots are from the actual Form 3520 and from the specific line instructions for that corresponding section.

[pk]

@Diegos , while agreeing with  my colleague @JotikaT2 , I  would  like to ask you to consider what  information the  form is trying to gather.  As you can see from the structure of the form and the instructions thereto, it is one that was designed for  dealing with  foreign  trusts which are associated with US persons  and has been co-opted to deal with gifts, bequeathals etc. to a US person from a foreign  person/ estate etc.  For  Part IV specifically all it is trying to get  is the information  about large  donors -- thus  the two step data collection ---  First  you check the box  for threshold determination ( US$ 100,000  ) and second , list ONLY those gifts/ bequeathals  above  a threshold of  US$5000.   The instructions also suggest that even after meeting the  qualifying  amount of US$1000,000,   you write on the first line  of the table  for line 54,  " No Gifts  or Bequests  exceed  $5000" .

Given the above  I would suggest  that in case  you have a mix of gifts  that are above  and below the  5000 threshold,  You list those that are equal or above US$5000 individually ( as required ) and then on the   fist empty line  in column (b)  write  --  XX number of gifts / bequests  are  below US$ 5000  and  ( if you so choose )  add the aggregate value of those  gifts .   This will provide all the info the form requires and additionally  match the total   of  all gifts/bequests for the current tax year.    This path also has the benefit of  recognizing the  all gifts  , just in case you get audited .

Does this make sense ?

Is there more one of us can do for you ?

pk