I'm with you on this. This has been a controversial topic on this forum for years -- and it still remains, not just a grey area, but turd brown. But amongst all the confusion, I guess one could self-assess and stretch the benefit of the doubt in their favor. However, as there's not a whole lot out there on the Internet to support this self-assessment, I wouldn't be totally comfortable ('tho the chance of being audited over this is probably zilch). But as dinga suggests, if the giftee has a foreign account, filter your gift thru this, on its way to Thailand via the giftee. This certainly would be a best option for me, with a Thai-US wife, with a US bank account ('tho my LTR visa eliminates the need for this option).