US Cross-Border Estate, Gift and Reporting Figures by Year (2015 to 2026)
The IRS resets most cross-border estate and gift figures every year, and the amount that governs is the one for the year of the gift, the death or the expatriation, not the year the question comes up. A US citizen married to someone who is not a citizen can give that spouse $194,000 free of gift tax in 2026, against $147,000 in 2015. A US person who receives more than $100,000 from a foreign individual or estate, or more than $20,573 from a foreign corporation or partnership, reports it on Form 3520 for 2026. A person who gives up citizenship or a long-held green card in 2026 is a covered expatriate if average annual net income tax over the prior five years is more than $211,000, and the first $910,000 of gain under the exit tax is excluded. The maximum FBAR penalty for a non-willful failure to report a foreign account is $16,536, unchanged from 2025, because the 2026 inflation adjustment was cancelled. The tables below give thirteen of these figures for every year from 2015 to 2026 and the IRS 7520 rate for every month from January 2015 to October 2026. Each amount is tied to the Revenue Procedure, statute or Federal Register notice it came from, and each was checked against that source on September 23, 2026.
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Choose the year of the gift, the death, the expatriation or the penalty assessment to see every figure for that year.
Annual gifts to a spouse who is not a US citizen
$147,000
Gift tax annual exclusion, per recipient
$14,000
Estate and gift tax basic exclusion
$5,430,000
Generation-skipping transfer tax exemption
$5,430,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$15,601
Covered expatriate test, average annual income tax
$160,000
Exit tax exclusion for a covered expatriate
$690,000
FBAR penalty maximum, non-willful
$10,000
FBAR penalty maximum, willful (or 50% of the balance if greater)
$100,000
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,100,000
Estate tax deferral, amount taxed at 2% interest
$1,470,000
Annual gifts to a spouse who is not a US citizen
$148,000
Gift tax annual exclusion, per recipient
$14,000
Estate and gift tax basic exclusion
$5,450,000
Generation-skipping transfer tax exemption
$5,450,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$15,671
Covered expatriate test, average annual income tax
$161,000
Exit tax exclusion for a covered expatriate
$693,000
FBAR penalty maximum, non-willful
$12,459
FBAR penalty maximum, willful (or 50% of the balance if greater)
$124,588
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,110,000
Estate tax deferral, amount taxed at 2% interest
$1,480,000
Annual gifts to a spouse who is not a US citizen
$149,000
Gift tax annual exclusion, per recipient
$14,000
Estate and gift tax basic exclusion
$5,490,000
Generation-skipping transfer tax exemption
$5,490,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$15,797
Covered expatriate test, average annual income tax
$162,000
Exit tax exclusion for a covered expatriate
$699,000
FBAR penalty maximum, non-willful
$12,663
FBAR penalty maximum, willful (or 50% of the balance if greater)
$126,626
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,120,000
Estate tax deferral, amount taxed at 2% interest
$1,490,000
Annual gifts to a spouse who is not a US citizen
$152,000
Gift tax annual exclusion, per recipient
$15,000
Estate and gift tax basic exclusion
$11,180,000
Generation-skipping transfer tax exemption
$11,180,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$16,076
Covered expatriate test, average annual income tax
$165,000
Exit tax exclusion for a covered expatriate
$711,000
FBAR penalty maximum, non-willful
$12,921
FBAR penalty maximum, willful (or 50% of the balance if greater)
$129,210
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,140,000
Estate tax deferral, amount taxed at 2% interest
$1,520,000
Annual gifts to a spouse who is not a US citizen
$155,000
Gift tax annual exclusion, per recipient
$15,000
Estate and gift tax basic exclusion
$11,400,000
Generation-skipping transfer tax exemption
$11,400,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$16,388
Covered expatriate test, average annual income tax
$168,000
Exit tax exclusion for a covered expatriate
$725,000
FBAR penalty maximum, non-willful
$13,247
FBAR penalty maximum, willful (or 50% of the balance if greater)
$132,469
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,160,000
Estate tax deferral, amount taxed at 2% interest
$1,550,000
Annual gifts to a spouse who is not a US citizen
$157,000
Gift tax annual exclusion, per recipient
$15,000
Estate and gift tax basic exclusion
$11,580,000
Generation-skipping transfer tax exemption
$11,580,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$16,649
Covered expatriate test, average annual income tax
$171,000
Exit tax exclusion for a covered expatriate
$737,000
FBAR penalty maximum, non-willful
$13,481
FBAR penalty maximum, willful (or 50% of the balance if greater)
$134,806
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,180,000
Estate tax deferral, amount taxed at 2% interest
$1,570,000
Annual gifts to a spouse who is not a US citizen
$159,000
Gift tax annual exclusion, per recipient
$15,000
Estate and gift tax basic exclusion
$11,700,000
Generation-skipping transfer tax exemption
$11,700,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$16,815
Covered expatriate test, average annual income tax
$172,000
Exit tax exclusion for a covered expatriate
$744,000
FBAR penalty maximum, non-willful
$13,640
FBAR penalty maximum, willful (or 50% of the balance if greater)
$136,399
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,190,000
Estate tax deferral, amount taxed at 2% interest
$1,590,000
Annual gifts to a spouse who is not a US citizen
$164,000
Gift tax annual exclusion, per recipient
$16,000
Estate and gift tax basic exclusion
$12,060,000
Generation-skipping transfer tax exemption
$12,060,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$17,339
Covered expatriate test, average annual income tax
$178,000
Exit tax exclusion for a covered expatriate
$767,000
FBAR penalty maximum, non-willful
$14,489
FBAR penalty maximum, willful (or 50% of the balance if greater)
$144,886
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,230,000
Estate tax deferral, amount taxed at 2% interest
$1,640,000
Annual gifts to a spouse who is not a US citizen
$175,000
Gift tax annual exclusion, per recipient
$17,000
Estate and gift tax basic exclusion
$12,920,000
Generation-skipping transfer tax exemption
$12,920,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$18,567
Covered expatriate test, average annual income tax
$190,000
Exit tax exclusion for a covered expatriate
$821,000
FBAR penalty maximum, non-willful
$15,611
FBAR penalty maximum, willful (or 50% of the balance if greater)
$156,107
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,310,000
Estate tax deferral, amount taxed at 2% interest
$1,750,000
Annual gifts to a spouse who is not a US citizen
$185,000
Gift tax annual exclusion, per recipient
$18,000
Estate and gift tax basic exclusion
$13,610,000
Generation-skipping transfer tax exemption
$13,610,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$19,570
Covered expatriate test, average annual income tax
$201,000
Exit tax exclusion for a covered expatriate
$866,000
FBAR penalty maximum, non-willful
$16,117
FBAR penalty maximum, willful (or 50% of the balance if greater)
$161,166
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,390,000
Estate tax deferral, amount taxed at 2% interest
$1,850,000
Annual gifts to a spouse who is not a US citizen
$190,000
Gift tax annual exclusion, per recipient
$19,000
Estate and gift tax basic exclusion
$13,990,000
Generation-skipping transfer tax exemption
$13,990,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$20,116
Covered expatriate test, average annual income tax
$206,000
Exit tax exclusion for a covered expatriate
$890,000
FBAR penalty maximum, non-willful
$16,536
FBAR penalty maximum, willful (or 50% of the balance if greater)
$165,353
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,420,000
Estate tax deferral, amount taxed at 2% interest
$1,900,000
Annual gifts to a spouse who is not a US citizen
$194,000
Gift tax annual exclusion, per recipient
$19,000
Estate and gift tax basic exclusion
$15,000,000
Generation-skipping transfer tax exemption
$15,000,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$20,573
Covered expatriate test, average annual income tax
$211,000
Exit tax exclusion for a covered expatriate
$910,000
FBAR penalty maximum, non-willful
$16,536
FBAR penalty maximum, willful (or 50% of the balance if greater)
$165,353
Estate tax credit for a nonresident who is not a citizen
$13,000
Special use valuation cap for farm and business real estate
$1,460,000
Estate tax deferral, amount taxed at 2% interest
$1,940,000
Estate, gift and reporting figures, 2015 to 2026
Each row is one figure and each column is the year it applies to. The FBAR rows follow the year each adjustment took effect, which the notes below explain.
Swipe the table sideways to see every year.
US estate, gift, expatriation and foreign-reporting figures in whole dollars for each year from 2015 to 2026
Figure
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
Annual gifts to a spouse who is not a US citizen
$147,000
$148,000
$149,000
$152,000
$155,000
$157,000
$159,000
$164,000
$175,000
$185,000
$190,000
$194,000
Gift tax annual exclusion, per recipient
$14,000
$14,000
$14,000
$15,000
$15,000
$15,000
$15,000
$16,000
$17,000
$18,000
$19,000
$19,000
Estate and gift tax basic exclusion
$5,430,000
$5,450,000
$5,490,000
$11,180,000
$11,400,000
$11,580,000
$11,700,000
$12,060,000
$12,920,000
$13,610,000
$13,990,000
$15,000,000
Generation-skipping transfer tax exemption
$5,430,000
$5,450,000
$5,490,000
$11,180,000
$11,400,000
$11,580,000
$11,700,000
$12,060,000
$12,920,000
$13,610,000
$13,990,000
$15,000,000
Form 3520 threshold, gifts from foreign individuals and estates
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
Form 3520 threshold, gifts from foreign corporations and partnerships
$15,601
$15,671
$15,797
$16,076
$16,388
$16,649
$16,815
$17,339
$18,567
$19,570
$20,116
$20,573
Covered expatriate test, average annual income tax
$160,000
$161,000
$162,000
$165,000
$168,000
$171,000
$172,000
$178,000
$190,000
$201,000
$206,000
$211,000
Exit tax exclusion for a covered expatriate
$690,000
$693,000
$699,000
$711,000
$725,000
$737,000
$744,000
$767,000
$821,000
$866,000
$890,000
$910,000
FBAR penalty maximum, non-willful
$10,000
$12,459
$12,663
$12,921
$13,247
$13,481
$13,640
$14,489
$15,611
$16,117
$16,536
$16,536
FBAR penalty maximum, willful (or 50% of the balance if greater)
$100,000
$124,588
$126,626
$129,210
$132,469
$134,806
$136,399
$144,886
$156,107
$161,166
$165,353
$165,353
Estate tax credit for a nonresident who is not a citizen
$13,000
$13,000
$13,000
$13,000
$13,000
$13,000
$13,000
$13,000
$13,000
$13,000
$13,000
$13,000
Special use valuation cap for farm and business real estate
$1,100,000
$1,110,000
$1,120,000
$1,140,000
$1,160,000
$1,180,000
$1,190,000
$1,230,000
$1,310,000
$1,390,000
$1,420,000
$1,460,000
Estate tax deferral, amount taxed at 2% interest
$1,470,000
$1,480,000
$1,490,000
$1,520,000
$1,550,000
$1,570,000
$1,590,000
$1,640,000
$1,750,000
$1,850,000
$1,900,000
$1,940,000
IRS 7520 rate by month, January 2015 to October 2026
The 7520 rate is the interest rate the IRS uses to value an annuity, a life estate, a term interest or a remainder, which makes it the rate behind every GRAT, charitable remainder trust and qualified personal residence trust. The rate was 0.4% from August to November 2020 and reached 5.8% in December 2023, so the same trust funded three years apart can produce very different gift values. The rate for October 2026 is 5.6%.
Swipe the table sideways to see every month.
The IRC section 7520 rate in percent for each month from January 2015 to 2026, from Table 5 of each monthly revenue ruling
Year
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
2015
2.2%
2.0%
1.8%
2.0%
1.8%
2.0%
2.2%
2.2%
2.2%
2.0%
2.0%
2.0%
2016
2.2%
2.2%
1.8%
1.8%
1.8%
1.8%
1.8%
1.4%
1.4%
1.6%
1.6%
1.8%
2017
2.4%
2.6%
2.4%
2.6%
2.4%
2.4%
2.2%
2.4%
2.4%
2.2%
2.4%
2.6%
2018
2.6%
2.8%
3.0%
3.2%
3.2%
3.4%
3.4%
3.4%
3.4%
3.4%
3.6%
3.6%
2019
3.4%
3.2%
3.2%
3.0%
2.8%
2.8%
2.6%
2.2%
2.2%
1.8%
2.0%
2.0%
2020
2.0%
2.2%
1.8%
1.2%
0.8%
0.6%
0.6%
0.4%
0.4%
0.4%
0.4%
0.6%
2021
0.6%
0.6%
0.8%
1.0%
1.2%
1.2%
1.2%
1.2%
1.0%
1.0%
1.4%
1.6%
2022
1.6%
1.6%
2.0%
2.2%
3.0%
3.6%
3.6%
3.8%
3.6%
4.0%
4.8%
5.2%
2023
4.6%
4.6%
4.4%
5.0%
4.4%
4.2%
4.6%
5.0%
5.0%
5.4%
5.6%
5.8%
2024
5.2%
4.8%
5.0%
5.2%
5.4%
5.6%
5.4%
5.2%
4.8%
4.4%
4.4%
5.0%
2025
5.2%
5.4%
5.4%
5.0%
5.0%
5.0%
5.0%
4.8%
4.8%
4.6%
4.6%
4.6%
2026
4.6%
4.6%
4.8%
4.6%
5.0%
5.0%
5.2%
5.2%
5.4%
5.6%
Notes on reading the figures
The 2018 figures were issued twice
The IRS published its 2018 figures in late 2017 in Rev. Proc. 2017-58, and in March 2018, after the Tax Cuts and Jobs Act, Rev. Proc. 2018-18 replaced three of them. The basic exclusion went from $5,600,000 to $11,180,000, the exit tax exclusion went down from $713,000 to $711,000, and the Form 3520 threshold for gifts from foreign corporations and partnerships went down from $16,111 to $16,076. The table uses the replacement amounts. Tables copied from the first release in late 2017 still show the superseded numbers.
The 2026 exemption of $15,000,000 is set by statute
The 2026 basic exclusion of $15,000,000 is not an inflation adjustment. Congress wrote the amount into the Internal Revenue Code in the 2025 tax law known as the One Big Beautiful Bill Act, and the IRS restated it in the changes section of its 2026 Revenue Procedure rather than in its list of adjusted amounts. The generation-skipping transfer exemption equals the basic exclusion, so the GST exemption is also $15,000,000 for 2026. Inflation indexing of both starts again in 2027. Articles that call the 2026 increase a cost-of-living adjustment have the amount right and the reason wrong.
FBAR penalties follow the assessment date
The FBAR maximums in the table sit under the year each inflation adjustment took effect, and the maximum that applies to a case is the one in force when the penalty is assessed, not the year the FBAR went unfiled. The adjustments for 2016, 2018 and 2019 took effect partway through the year, on August 1, 2016, March 19, 2018 and October 10, 2019. A penalty assessed in June 2019 therefore still carried the 2018 non-willful maximum of $12,921. The adjusted amounts apply only to violations after November 2, 2015. No adjustment was made for 2026, because the federal government cancelled the 2026 civil penalty inflation adjustment for every agency in April 2026, so the 2025 amounts of $16,536 and $165,353 remain the latest. For a willful violation the maximum is $165,353 or 50% of the account balance, whichever is greater.
Two figures are never adjusted
The $100,000 Form 3520 threshold for gifts and bequests from foreign individuals and foreign estates comes from a 1997 IRS notice, not from the Code, and the notice provides no indexing. The amount has stood since 1997, while the separate threshold for gifts from foreign corporations and partnerships has doubled from its $10,000 base to $20,573. The $13,000 estate tax credit for a nonresident who is not a US citizen has not changed since 1988. The credit covers the tax on about $60,000 of US property, while the exclusion for a citizen or resident grew from $5,430,000 to $15,000,000 over the years in this table. Both unindexed amounts appear in every column for convenience.
The figures come from the annual inflation Revenue Procedures, listed below by the first page of each in the Internal Revenue Bulletin. The section and pin page for every amount are in the data files.
91 FR 25936 (May 12, 2026), reporting OMB memorandum M-26-11 of April 17, 2026, which cancelled the 2026 civil penalty inflation adjustment
The 7520 rates come from Table 5 of each monthly applicable federal rate revenue ruling, Rev. Rul. 2015-1 through Rev. Rul. 2026-19. The ruling and bulletin page for each month are in the 7520 rates file. The table caption in 2018-36 I.R.B. misprints the September 2018 ruling as Rev. Rul. 2018-21, and the dataset cites the correct Rev. Rul. 2018-23.
Data and citation
The data is free to reuse with credit. The figures CSV file and JSON file hold all 145 rows with the authority, the link and a note for each amount, the 7520 rates file holds all 142 months, and the data dictionary defines each column. The full dataset, including the saved text of every Revenue Procedure excerpt, statute and Federal Register notice, is also kept on GitHub (Microsoft’s public archive, also used by the Library of Congress) and Kaggle (Google’s public data platform).
Please cite this page as Klagge, Kevin D., US Cross-Border Estate, Gift and Reporting Figures, 2015 to 2026, StepUpLaw, https://stepuplaw.com/data/us-crossborder-estate-gift-figures/ (DOI 10.5281/zenodo.22922297).
Klagge, Kevin D., US Cross-Border Estate, Gift and Reporting Figures, 2015 to 2026, StepUpLaw, https://stepuplaw.com/data/us-crossborder-estate-gift-figures/ (DOI 10.5281/zenodo.22922297).
The figures are updated each autumn when the IRS publishes the next year’s inflation Revenue Procedure, and the 7520 table is updated monthly. It was last reviewed on September 23, 2026. Corrections are welcome at [email protected].
Compiled by Kevin D. Klagge, Esq., Fla. Bar No. 99502. This is reference information, not legal advice, and reading it creates no attorney-client relationship. Whether a figure applies to a particular gift, estate or expatriation depends on facts a table cannot hold, including citizenship, residence, the date of the transfer and the treaty position. Read the cited source before relying on any amount.
