PRIA Logo™
Title 26 — Internal Revenue CodeRelease 119-73

§6039F Notice of Large Gifts Received From Foreign Persons

Title 26 › Subtitle Subtitle F— Procedure and Administration › Chapter 61— INFORMATION AND RETURNS › Subchapter A— Returns and Records › Part III— INFORMATION RETURNS › Subpart A— Information Concerning Persons Subject to Special Provisions › § 6039F

Last updated Apr 6, 2026|Official source

Summary

If you are a U.S. person and the gifts you receive from foreign persons in a year add up to more than $10,000 (a base amount that is adjusted for inflation each year), you must report information about each gift to the IRS. A foreign gift is an amount from a non-U.S. person that you treat as a gift or bequest; certain tuition or medical payments and properly disclosed trust distributions do not count. If you fail to report on time, the IRS decides the tax treatment of the gift, and you owe 5 percent of the gift for each month the failure continues, up to 25 percent total. The penalty is excused if you show reasonable cause and not willful neglect.

Full Legal Text

Title 26, §6039F

Internal Revenue Code — Source: USLM XML via OLRC

(a)If the value of the aggregate foreign gifts received by a United States person (other than an organization described in section 501(c) and exempt from tax under section 501(a)) during any taxable year exceeds $10,000, such United States person shall furnish (at such time and in such manner as the Secretary shall prescribe) such information as the Secretary may prescribe regarding each foreign gift received during such year.
(b)For purposes of this section, the term “foreign gift” means any amount received from a person other than a United States person which the recipient treats as a gift or bequest. Such term shall not include any qualified transfer (within the meaning of section 2503(e)(2)) or any distribution properly disclosed in a return under section 6048(c).
(c)(1)If a United States person fails to furnish the information required by subsection (a) with respect to any foreign gift within the time prescribed therefor (including extensions)—
(A)the tax consequences of the receipt of such gift shall be determined by the Secretary, and
(B)such United States person shall pay (upon notice and demand by the Secretary and in the same manner as tax) an amount equal to 5 percent of the amount of such foreign gift for each month for which the failure continues (not to exceed 25 percent of such amount in the aggregate).
(2)Paragraph (1) shall not apply to any failure to report a foreign gift if the United States person shows that the failure is due to reasonable cause and not due to willful neglect.
(d)In the case of any taxable year beginning after December 31, 1996, the $10,000 amount under subsection (a) shall be increased by an amount equal to the product of such amount and the cost-of-living adjustment for such taxable year under section 1(f)(3), except that subparagraph (A)(ii) thereof shall be applied by substituting “1995” for “2016”.
(e)The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this section.

Legislative History

Notes & Related Subsidiaries

Inflation Adjusted Items for Certain YearsFor inflation adjustment of certain items in this section, see Revenue Procedures listed in a table under section 1 of this title.

Editorial Notes

Codification Another section 6039F was renumbered section 6039G of this title.

Amendments

2017—Subsec. (d). Pub. L. 115–97 substituted “subparagraph (A)(ii) thereof shall be applied by substituting ‘1995’ for ‘2016’ ” for “subparagraph (B) thereof shall be applied by substituting ‘1995’ for ‘1992’ ”.

Statutory Notes and Related Subsidiaries

Effective Date

of 2017 AmendmentAmendment by Pub. L. 115–97 applicable to taxable years beginning after Dec. 31, 2017, see section 11002(e) of Pub. L. 115–97, set out as a note under section 1 of this title.

Effective Date

Pub. L. 104–188, title I, § 1905(c), Aug. 20, 1996, 110 Stat. 1913, provided that: “The

Amendments

made by this section [enacting this section] shall apply to amounts received after the date of the enactment of this Act [Aug. 20, 1996] in taxable years ending after such date.”

Reference

Citations & Metadata

Citation

26 U.S.C. § 6039F

Title 26 — Internal Revenue Code

Last Updated

Apr 6, 2026

Release point: 119-73