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Noncitizen Spouse Gift Limit 2026: $194,000

Updated October 29, 2026. Quick answer: The annual gift tax exclusion for gifts to a spouse who is not a U.S. citizen is $194,000 for 2026, against $19,000 for a gift to anyone else, per Rev. Proc. 2025-32. The two differ because gifts to a noncitizen spouse do not qualify for the marital deduction. The 2027 version has its own page, the noncitizen spouse gift limit for 2027.

The 2026 amounts

GiftAnnual exclusionSource
Gift to any person (2026)$19,000Rev. Proc. 2025-32, section 4, item .42(1)
Gift to a spouse who is not a U.S. citizen (2026)$194,000Rev. Proc. 2025-32, section 4, item .42(2)
Amounts printed in the statute: $10,000 for others, $100,000 for a noncitizen spouse$10,000 and $100,00026 U.S.C. 2503(b), 2523(i)

The IRS wrote both amounts in the same section. For everyone else: “For calendar year 2026, the first $19,000 of gifts to any person (other than gifts of future interests in property) are not included in the total amount of taxable gifts under § 2503 made during that year.” For a spouse who is not a citizen: “the first $194,000 (instead of the amount provided in paragraph (1) of this section 4.42) of gifts to a spouse who is not a citizen of the United States (other than gifts of future interests in property) are not included in the total amount of taxable gifts under §§ 2503 and 2523(i)(2) made during that year.”

Why the noncitizen spouse has a different number

Section 2523(i) of the Internal Revenue Code takes away the marital deduction for these gifts: “If the spouse of the donor is not a citizen of the United States” then “(1) no deduction shall be allowed under this section,” and the annual exclusion rule is changed by “section 2503(b) shall be applied with respect to gifts which are made by the donor to such spouse” using $100,000 in place of $10,000. Those are the base amounts. Like the ordinary exclusion they are adjusted for inflation, which is how they became $194,000 and $19,000 for 2026.

How the ordinary exclusion is indexed

Section 2523(i)(2) applies section 2503(b), so the same indexing and rounding rule governs both figures. Section 2503(b)(2) ends: “If any amount as adjusted under the preceding sentence is not a multiple of $1,000, such amount shall be rounded to the next lowest multiple of $1,000.” The lifetime exemption is a different question, covered on the lifetime gift and estate tax exemption page.

Common mistakes

  • Using $19,000 for a gift to a noncitizen spouse. For 2026 the amount is $194,000, and only gifts above it are included in the year’s taxable gifts.
  • Assuming the marital deduction applies. The statute denies it when the receiving spouse is not a U.S. citizen.
  • Using the base amounts printed in the statute. The $10,000 and $100,000 are adjusted each year.

Related: the estate tax exemption, the lifetime gift and estate tax exemption, the gift tax annual exclusion, and the noncitizen spouse gift limit for 2027.

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Sources

  • Internal Revenue Service, Rev. Proc. 2025-32, tax year 2026 inflation-adjusted amounts, as modified by the One, Big, Beautiful Bill Act: www.irs.gov
  • 26 U.S.C. 2523, Gift to spouse (U.S. Code, 2024 edition, U.S. Government Publishing Office): www.govinfo.gov
  • 26 U.S.C. 2503, Taxable gifts (U.S. Code, 2024 edition, U.S. Government Publishing Office): www.govinfo.gov

Read from the primary documents linked above on October 29, 2026. General information, not tax advice. Your own facts decide the outcome, and a preparer or the IRS itself is the right place to confirm anything consequential.

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