Streamlined filing: getting current, penalty-free from abroad.
If you have missed US filings while living abroad, for years, or forever, the Streamlined Foreign Offshore Procedures are the IRS's route back: three years of returns, six years of FBARs, and no penalties, provided the failure was non-willful.
Built for people who simply didn't know
Most people in this position aren't dodging anything, they moved abroad, or were born abroad to an American parent, and nobody told them the filing obligation followed. The Streamlined programme exists exactly for that, and it wipes the failure-to-file, failure-to-pay and FBAR penalties in full.
The package is specific: 3 years of delinquent or amended returns, six years of FBARs, and a certification of non-willfulness on Form 14653 that has to be written carefully, it is a sworn statement, not a formality.
- Eligibility review before anything is filed
- Three years of federal returns, prepared or amended
- Six years of FBARs
- Form 14653 non-willfulness certification, drafted with you
Do it once, before the letter arrives
Streamlined is only available before the IRS contacts you. UK banks already report US-person accounts under FATCA, so waiting is a strategy with a deadline you don't control.
We prepare the entire package, every return, every FBAR, the certification and the submission, with one tax accountant on your file throughout.
What the process actually looks like
A scoping call establishes eligibility and the fee. Document gathering runs through our secure portal against a checklist built for your situation. We prepare the three returns and six FBARs, draft the Form 14653 narrative with you, and file the complete package.
Most engagements run six to ten weeks end to end, driven mainly by how quickly bank statements arrive. The most common outcome surprises people: with foreign tax credits applied, many Streamlined filers owe nothing at all.
- Six to ten weeks from scoping call to submission
- Secure portal, one tailored document checklist
- The 14653 narrative drafted with you, not for you
- Ongoing annual filing quoted before you commit
How it runs
- Confirm the route is the right one
Establish that the failure to file was non-wilful and that the IRS has not made contact. Both are eligibility conditions, and using the programme when neither holds makes the position worse rather than better.
- Establish which route applies
Living abroad and meeting the 330-day non-residency test puts you on the Foreign route, where penalties are waived outright. Living in the US puts you on the Domestic route, which charges 5% of the highest aggregate value.
- Reconstruct the years
Gather income, account and asset records for the 3 tax years and 6 FBAR years the package covers. This is the slow part - recovering old statements, not completing the forms.
- Prepare the returns and FBARs
3 delinquent or amended returns with foreign tax credits applied across them, and 6 years of FinCEN Form 114. Most filers owe little or nothing once the credits are computed.
- Draft the Form 14653 certification
A factual narrative of why the filings were missed, signed under penalty of perjury. It is the document the IRS judges the submission against, so it is drafted with you rather than for you.
- Submit, then file forward
The package goes in as one submission. There is no acceptance letter - processed returns and silence is the normal outcome. Ordinary annual filing resumes from the following year.
IRS Streamlined Filing from the UK
How to catch up on missed US returns and FBARs without penalties, and who qualifies.
Questions we are asked most
The ones that come up in almost every first conversation about streamlined catch-up filing.
The IRS does not acknowledge Streamlined submissions on a fixed timetable, and no news is normally good news rather than a problem.
The reconstruction of prior years is usually what governs the pace, particularly where old statements have to be recovered.
Yes. The Domestic and Foreign procedures differ, and the domestic version carries a penalty on the highest aggregate account balance where the foreign one does not.
Which applies turns on your physical presence over the relevant years, not on citizenship.
Then Streamlined is the wrong route, and there are other disclosure paths designed for that situation.
This is worth getting right before filing anything, because using the wrong programme is materially worse than using none yet.
3 years of tax returns, 6 years of FBARs, and a signed certification explaining why the failure to file was not deliberate.
Where the IRS accepts it, the failure-to-file and FBAR penalties that would otherwise apply are waived.
The test is whether your failure to file was non-wilful - typically someone who simply did not know the obligation existed.
If there is history suggesting you knew and chose not to act, this is the wrong route, and using it anyway makes the position considerably worse. That judgement belongs before you submit, not after.
Frequently very little. Once foreign tax credits are applied across the reconstructed years, the tax actually due is often small or nil.
It is the unfiled disclosure forms rather than the tax that create the real exposure.
We deal with both rather than fixing one side and leaving the other open for someone to find later.
Where the same history spans both authorities, the sequencing of the two disclosures matters.
Related services
Most positions touch more than one of these. We prepare them from the same file.
Years behind and not sure how bad it is?
It is almost always more fixable than it feels. Tell us your situation and we will map the clean-up route and what it involves.