---
kind: "section"
citation: "26 U.S.C. § 6039F"
title: "26"
title_heading: "Internal Revenue Code"
number: "6039F"
heading: "Notice of large gifts received from foreign persons"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/6039F"
units:
  - "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. Notice of large gifts received from foreign persons

- (a) **In general—** If the value of the aggregate [foreign](/usc/26/7701.md?p=a-5) gifts received by a [United States person](/usc/26/7701.md?p=a-30) (other than an organization described in [section 501(c)](/usc/26/501.md?p=c) and exempt from tax under [section 501(a)](/usc/26/501.md?p=a)) during any [taxable year](/usc/26/7701.md?p=a-23) exceeds $10,000, such [United States person](/usc/26/7701.md?p=a-30) shall furnish (at such time and in such manner as the [Secretary](/usc/26/7701.md?p=a-11-B) shall prescribe) such information as the [Secretary](/usc/26/7701.md?p=a-11-B) may prescribe regarding each [foreign](/usc/26/7701.md?p=a-5) gift received during such year.
- (b) **Foreign gift—** For purposes of this section, the term “[foreign](/usc/26/7701.md?p=a-5) gift” means any amount received from a [person](/usc/26/7701.md?p=a-1) other than a [United States person](/usc/26/7701.md?p=a-30) 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)](/usc/26/2503.md?p=e-2)) or any distribution properly disclosed in a return under [section 6048(c)](/usc/26/6048.md?p=c).
- (c) **Penalty for failure to file information—**
  - (1) **In general—** If a [United States person](/usc/26/7701.md?p=a-30) fails to furnish the information required by [subsection (a)](#a) with respect to any [foreign](/usc/26/7701.md?p=a-5) gift within the time prescribed therefor ([including](/usc/26/7701.md?p=c) extensions)—
    - (A) the tax consequences of the receipt of such gift shall be determined by the [Secretary](/usc/26/7701.md?p=a-11-B), and
    - (B) such [United States person](/usc/26/7701.md?p=a-30) shall pay (upon notice and demand by the [Secretary](/usc/26/7701.md?p=a-11-B) and in the same manner as tax) an amount equal to 5 percent of the amount of such [foreign](/usc/26/7701.md?p=a-5) gift for each month for which the failure continues (not to exceed 25 percent of such amount in the aggregate).
  - (2) **Reasonable cause exception—** [Paragraph (1)](#c-1) shall not apply to any failure to report a [foreign](/usc/26/7701.md?p=a-5) gift if the [United States person](/usc/26/7701.md?p=a-30) shows that the failure is due to reasonable cause and not due to willful neglect.
- (d) **Cost-of-living adjustment—** In the case of any [taxable year](/usc/26/7701.md?p=a-23) beginning after December 31, 1996, the $10,000 amount under [subsection (a)](#a) shall be increased by an amount equal to the product of such amount and the cost-of-living adjustment for such [taxable year](/usc/26/7701.md?p=a-23) under [section 1(f)(3)](/usc/26/1.md?p=f-3), except that subparagraph (A)(ii) thereof shall be applied by substituting “1995” for “2016”.
- (e) **Regulations—** The [Secretary](/usc/26/7701.md?p=a-11-B) shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this section.

## Source credit

(Added Pub. L. 104–188, title I, § 1905(a), Aug. 20, 1996, 110 Stat. 1913; amended Pub. L. 115–97, title I, § 11002(d)(13), Dec. 22, 2017, 131 Stat. 2062.)

## Notes

### Inflation Adjusted Items for Certain Years

For 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 Amendment

Amendment 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.”