[schinakl]

A father who is a Dutch citizen wants to transfer $500,000 (or portions of it) to his daughter, who is a resident alien (green card) living in the US, and she's married to a US citizen.

1. Does the daughter (or her US husband) have any tax liability in the US?
2. The receiving US bank will report it to the IRS. Yes?
3. Does the daughter have to report it to the IRS? Form 3520?
4. Does the father have any tax liability in the US?
5. Is there an advantage to bring in smaller amounts on an annual basis?
6. In case the father dies and his will gives his daughter the $500,000 - what are the tax consequences for her?

[MukatA]

1. The receiver of the gift does not pay any gift tax in the U.S. So the daughter does not have any gift tax liability.
2-3. IRS wants to make sure that the amount is actually a gift. So if the gift amount exceeds $100,000 in a year, the daughter must file Form 3520: Notice of Large Gifts Received from Foreign Persons.
4. In the U.S. the donor of the gift has to pay gift tax. But since the father is a foreign person and is not subject to U.S. taxes, so he does not have any tax liability.
5. No there is no advantage.
6. Just like gifts, the receiver of any inherited money or property does not pay any tax.

Read Your U.S. Tax Return: The U.S. Gift Tax
About inheritances: Your U.S. Tax Return: Tax on Inheritances

[hotchilipepper]

Does the same rule apply to money transfer out of a US bank account, owned by foreign national with no SSN, to the son, who is a US citizen as gift?