StepUpLaw/us-crossborder-estate-gift-figures

US Cross-Border Estate, Gift and Reporting Figures, 2015 to 2026

This Hugging Face copy holds figures.csv, figures.json, section7520_rates.csv, schema.json and datapackage.json. The saved text of every source and the build tools are in the GitHub repository.

A year-by-year table of the US estate, gift, expatriation and foreign-reporting figures that cross-border planners quote. These are the numbers that matter to a person married to someone who is not a US citizen, a US person who receives a gift or inheritance from abroad, someone giving up US citizenship or a long-held green card, and anyone with a foreign bank account. Every amount is tied to the primary source it came from, which is the annual inflation Revenue Procedure (by section and Internal Revenue Bulletin page), the statute, or the Federal Register. The dataset also has a monthly IRC 7520 rate table running from January 2015 to October 2026.

Compiled by Kevin D. Klagge, Esq., a Florida estate planning attorney whose practice includes international and cross-border clients (Klagge Law, PLLC). Built and checked on September 23, 2026.

• Canonical page with the tables and the citation: https://stepuplaw.com/data/us-crossborder-estate-gift-figures/
• Source repository: https://github.com/stepuplaw/us-crossborder-estate-gift-figures

FINDINGS.md has the pivoted table, the conflicts found on widely quoted web pages, and the ten findings most likely to surprise a reader.

Files

Path	What it is
data/figures.csv, data/figures.json	145 rows: 13 figures, one row per (figure, year) for 2015 to 2026, plus one row for the unindexed nonresident alien estate credit
data/section7520_rates.csv	142 rows: the IRC 7520 rate for each month from January 2015 to October 2026
data/sources/revproc-*-excerpts.txt	The relevant paragraphs of each annual inflation Rev. Proc. (2014-61 through 2025-32, plus 2018-18), with section and IRB page
data/sources/notice-97-34-sec-VI-excerpt.txt	Notice 97-34, section VI (source of the $100,000 Form 3520 threshold for gifts from individuals)
data/sources/statute-*.txt	Statute text: 26 U.S.C. 877, 877A, 2010, 2032A, 2102, 2503, 2523, 2631, 6039F, 6048, 6166, 6601, 6677, 7520; 31 U.S.C. 5321; 31 CFR 1010.821; Pub. L. 119-21 sec. 70106
data/sources/fr-*-excerpt.txt	Federal Register FBAR penalty adjustment rows (2016 to 2025) and the 2026 cancellation notice
data/sources/section7520-revrul-excerpts.txt	The "Rate Under Section 7520" table from each monthly revenue ruling
data/sources/US-popular-*.txt	Widely quoted web pages compared in FINDINGS.md (text as retrieved September 23, 2026)
data/schema.json	Data dictionary for both CSV files as Frictionless Table Schemas
data/datapackage.json	Frictionless Data Package descriptor for both CSV files
tools/	The code that built everything from the sources (see Method), plus write_metadata.py for the schema and package files
notebooks/crossborder-figures-overview.ipynb	A short notebook that loads the CSV files and prints the pivoted table and the 7520 range
FINDINGS.md	The pivoted table, conflicts with widely quoted pages, and findings
progress.log	One line per figure family as it was completed

Columns: figures.csv / figures.json

Column	Meaning
figure_id	Stable identifier, e.g. gift_noncitizen_spouse
figure_name	Plain-English name with the Code section
year	The year the amount applies to: calendar year of the gift, death or expatriation, or the taxable year (Form 3520 thresholds). For FBAR penalties, the year the adjustment took effect (penalties are keyed to the assessment date; see note). Blank for nra_estate_credit, which is one row for all years
amount	Whole US dollars
unit	Always USD
authority	Where the amount comes from: Rev. Proc. number, section, IRB issue and first page, then the pin page where known (for example Rev. Proc. 2025-32, sec. 4.42, 2025-45 I.R.B. 695, 704); or a statute; or a Federal Register cite
authority_url	IRS IRB PDF, federalregister.gov document link, or GovInfo statute page
note	Scope, caveats, superseded amounts, and how carried-over or derived rows were determined

JSON has the same fields. year is null for the single nra_estate_credit row.

Figures

figure_id	Source type
gift_annual_exclusion	Rev. Proc., each year
gift_noncitizen_spouse	Rev. Proc., each year
basic_exclusion	Rev. Proc., each year; 2026 set by statute (Pub. L. 119-21 sec. 70106) and restated in Rev. Proc. 2025-32 sec. 2.14
gst_exemption	IRC 2631(c) makes it equal to the basic exclusion amount; only Rev. Proc. 2025-32 (2026) states it directly
section_2032a_cap	Rev. Proc., each year
section_6166_2pct_amount	Rev. Proc., each year (the indexed form of the $1,000,000 in IRC 6601(j)(2))
form3520_foreign_gift_corp_partnership	Rev. Proc., each year (IRC 6039F(d) indexing of the $10,000 in 6039F(a))
form3520_foreign_gift_individual	Notice 97-34, sec. VI.B.1; $100,000, not indexed
expatriation_avg_tax_liability	Rev. Proc., each year
expatriation_877a_exclusion	Rev. Proc., each year
fbar_penalty_nonwillful_max	31 U.S.C. 5321(a)(5)(B)(i) for 2015; FinCEN/Treasury Federal Register adjustments 2016 to 2025; 2025 amount carried to 2026 (adjustment cancelled)
fbar_penalty_willful_max_floor	Same, for the dollar amount in 5321(a)(5)(C)(i)(I). The willful maximum is the greater of this amount or 50% of the balance
nra_estate_credit	IRC 2102(b)(1); $13,000, not indexed, one row

section_6039f_penalty_note is left out on purpose. It would belong only if an indexed amount existed, and none does: the IRC 6039F(c) penalty is 5% of the gift per month, capped at 25%, with no dollar figure to index (statute text in data/sources/statute-usc-26-6039F.txt).

Columns: section7520_rates.csv

Column	Meaning
year, month	The month the rate applies to
rate_percent	The 7520 rate, in percent (e.g. 5.6)
revenue_ruling	The monthly AFR revenue ruling that announced it
irb_cite	IRB issue and first page of the ruling. October 2026 (Rev. Rul. 2026-19) is not yet in a bulletin issue; it comes from the irs.gov irs-drop release
table	The table in the ruling (always Table 5)
authority_url	IRB PDF, or the irs-drop PDF for October 2026
note	Set only for September 2018, where the IRB table caption misprints the ruling number

Method

1. Revenue Procedures. The Internal Revenue Bulletin issues for 2014 to 2026 were read from the local IRB corpus (us-law.db, corpus irb) using lawcorpus.section_text() (tools/cache_irb.py). tools/extract_revprocs.py finds each Rev. Proc. in its issue and splits it into its numbered items. It then keeps the paragraphs that contain a dollar amount for each figure, skipping table-of-contents lines. tools/revproc_figures.py parses the amount with a regex specific to each figure. It also checks that the paragraph names the expected year and fails on any unmatched paragraph. No amount was typed by hand.
2. IRB pages. Each Rev. Proc.'s first page comes from the IRB cumulative finding lists (e.g. "2025-32, 2025-45 I.R.B. 695"). Pin pages come from the page markers in the extracted text. Older bulletins print these markers at the foot of each page and newer ones at the head, so for each issue the script uses whichever reading reproduces the official first page.
3. 2018. Rev. Proc. 2017-58 set the 2018 amounts. After Pub. L. 115-97, Rev. Proc. 2018-18 superseded some of them. The table uses 2018-18 for the three items it changed (basic exclusion, 877A exclusion, 6039F threshold) and 2017-58 for the rest. The notes give the superseded amounts.
4. Statutes come from the local USC corpus (2024 edition), plus the enacted text of Pub. L. 119-21 sec. 70106 for the 2026 basic exclusion (tools/save_statutes.py).
5. FBAR penalties. The local Federal Register corpus holds IRS rules only. So the FinCEN and Treasury civil penalty adjustment rules were found through the federalregister.gov API and read from GovInfo's copy of each Federal Register issue (tools/fr_fetch.py). tools/fbar_figures.py then parses the 31 U.S.C. 5321(a)(5) rows. For 2026, no FinCEN adjustment appears in the Federal Register through September 23, 2026. Notices from other agencies (for example PBGC, 91 FR 25936) report that OMB memorandum M-26-11 of April 17, 2026 cancelled the 2026 adjustment, so the 2025 amounts carry over.
6. 7520 rates. tools/rates7520.py reads Table 5 of every monthly AFR revenue ruling in the corpus. It takes the ruling number from the ruling's own header, not the table caption. October 2026 is not in the corpus yet, so it comes from the irs.gov irs-drop PDF of Rev. Rul. 2026-19 (tools/irs_drop.py, text extracted with PyMuPDF). As a check on the extraction, all 142 months were compared with the Evans Estate Law Resources 7520 chart (tools/compare_7520.py). Every month matched.
7. Build. tools/build_dataset.py assembles figures.csv and figures.json, checks that each (figure, year) pair has exactly one source row, and checks for dash characters. tools/make_report.py renders the report from tools/report_template.md, published here as FINDINGS.md.

To rebuild: run cache_irb.py, extract_revprocs.py, revproc_figures.py, save_statutes.py, fbar_figures.py (after fr_fetch.py text ...), rates7520.py, build_dataset.py, then make_report.py (which renders the findings report from tools/report_template.md). The rebuild needs the local IRB and USC corpora, which are not part of this repository; the saved excerpts in data/sources/ are what each figure rests on. The scripts use system python3, with the caselaw venv's site-packages appended for zstandard and pymupdf.

Conventions and caveats

• Source excerpts keep the source wording, except that ligatures are expanded, soft hyphens are dropped, and em and en dashes are converted to hyphens to match house style.
• The GST exemption for 2015 to 2025 is not stated in any Rev. Proc. It is derived from IRC 2631(c), which sets it equal to the basic exclusion amount. The authority field says so.
• FBAR adjustments apply to penalties assessed after the adjustment's effective date, for violations after November 2, 2015. In 2016, 2018 and 2019 the adjustment took effect partway through the year (August 1, March 19 and October 10), so earlier assessments that year used the prior amounts.

Not legal advice

This is reference data, not legal advice, and using it creates no attorney-client relationship. Check the current Revenue Procedure, statute or Federal Register notice before relying on a figure.

License

The data is licensed CC BY 4.0. You may use it commercially, modify it and build products on it with credit. The statute text and government excerpts in data/sources/ are US government works.

Citation

Klagge, Kevin D. US Cross-Border Estate, Gift and Reporting Figures, 2015 to 2026. StepUpLaw, 2026. https://stepuplaw.com/data/us-crossborder-estate-gift-figures/

CITATION.cff holds the same citation in machine-readable form. Corrections are welcome at office@stepuplaw.com.