The person named on an international wire is not necessarily the person who gave you the money. A family member may transmit another person’s funds. Before preparing foreign-gift reporting, trace ownership and determine whether the senders made independent gifts or acted as intermediaries.
Our Form 3520 guide covers the form’s broader rules. This article explains how to organize a transfer chain when several names appear in the bank records.
Map the Funds From Their Owner to the Recipient
For each payment, identify four roles: the original owner, any transmitting intermediary, the receiving-account holder, and the person entitled to keep the money. One person can occupy several roles. Several people can appear in the bank trail without each being a separate donor.
- Original owner: who owned the funds before the arrangement?
- Intermediary: who received and transmitted them on that owner’s instructions?
- Recipient: when did the intended beneficiary obtain ownership?
- Purpose: was the transfer a gift, loan, reimbursement, or another transaction?
Keep the bank route and the ownership explanation alongside one another. Neither should be rewritten merely to match a preferred filing result.
A Fictional Transfer Chain
A parent supplies funds to a sibling, who sends them to the parent’s adult child. The sibling says the money was transmitted on the parent’s instructions and was never intended as the sibling’s own gift. Review the parent’s source statement, the sibling’s receipt and outgoing wire, and the written instructions together.
Compare that with a sibling making a gift from the sibling’s independently owned savings. The bank may show the same sender in both examples, but the ownership history is different. A donor declaration unsupported by the transaction chain leaves that distinction unresolved.
How Related Donors and Intermediaries Affect Aggregation
For the $100,000 foreign individual/estate gift threshold, the Form 3520 instructions require aggregation when the recipient knows or has reason to know donors are related, or one acts as a nominee or intermediary for another. Part IV also asks about nominees or intermediaries. See the IRS Form 3520 instructions.
Separate wires do not establish separate reporting allowances. Conversely, sharing a sending country or bank does not establish that otherwise independent donors are related. The facts must support the connection. Corporate and partnership sources have different rules, so identifying an ultimate business source can materially change the review.
Build One Transfer Ledger With Supporting Documents
Use one row for each receipt, with these fields:
- Date, currency, amount, and receiving-account record.
- Sender’s legal name, original-language name, and English spelling variations.
- Source owner and each intermediary in the chain.
- Relationships among senders and the recipient.
- Purpose, repayment terms, and supporting document references.
- Unresolved questions about timing, ownership, exchange rates, or fees.
Preserve sender statements and wire advices, not only the receiving statement. Reconcile fees separately so the ledger distinguishes the source amount, deductions, and amount credited. Where names differ between documents, record the evidence connecting them rather than silently merging entries.
A complete ledger also prevents duplicate statement copies from becoming duplicate gifts. Keep each underlying transaction once, with references to any copies that corroborate it.
Transfer Routing and Local Exchange Rules
The U.S. ownership review does not decide whether the sending arrangement complied with another country’s exchange-control rules. For China-related transfers, see our China-to-U.S. reporting article. Document the actual route and obtain appropriate local-law advice where necessary.
Frequently Asked Questions
Can I identify every wire sender as a separate donor?
Only if the facts support that characterization. Ask whether each person owned the funds and intended to give them.
Should I combine two English spellings of a name?
Verify the identity first. Original-language names and account records can help explain variations.
What if an intermediary cannot provide a statement?
Identify the missing link, preserve available evidence, and explain the limitation. Do not invent an ownership history.
Get the Source-of-Funds Questions Reviewed
Schedule a $500 Tax Attorney Consultation with Philip M. Falco, Attorney & CPA. The fee includes up to one hour of combined review, analysis, preparation, and telephone consultation. Form preparation, filing, and ongoing representation require a separate written engagement.
General information, updated October 9, 2026. The illustration is fictional. Donor identity, aggregation, and reportable values depend on the evidence and applicable law.