Skip to content
IRS Streamlined Filing Procedures
Home/Services/IRS Streamlined Filing Procedures

IRS Streamlined Filing Procedures

Specialized IRS catch-up programs for US citizens and residents with non-willful offshore reporting omissions.

IRS Streamlined Filing Procedures

0%

Foreign Penalty

For US citizens and residents living abroad, FBAR and FATCA reporting is complicated enough that many fall out of compliance without meaning to. If you have failed to report foreign income or offshore accounts, the standard penalties are severe, but the IRS offers a second chance to those who acted in good faith.

The Streamlined Filing Procedures are the main route for non-willful taxpayers to come forward voluntarily. We reconstruct your records and prepare the certification these programs require, so you can catch up on years of missed filings while reducing or eliminating the standard $10,000-per-violation penalties.

Our Methodology

How we deliver this service.

A rigorous, phase-driven process ensures nothing is missed and every position is defensible.

01

Non-Willful Certification

We review your facts and circumstances to determine whether your errors meet the 'non-willful' legal standard the program requires.

02

Transcript & Record Audit

We pull your IRS transcripts and reconstruct your global financial records to identify every missing reporting event.

03

Income Tax Preparation (3 Years)

We prepare 3 years of late or amended income tax returns, including all required international disclosure forms.

04

FBAR Preparation (6 Years)

We prepare 6 years of delinquent Foreign Bank Account Reports (FinCEN 114), verifying the maximum balance on every account.

05

Certification Narrative Drafting

We draft the required 'Non-Willful Certification' statement, documenting the specific reasons for the previous omissions.

06

Submission & Notice Handling

Our firm handles the final submission and any subsequent IRS notices until your account is back in good standing.

The 0% penalty route for expats.

Foreign Expat Benefit

Streamlined Foreign Offshore (SFO)

The 0% penalty route for expats.

The most generous catch-up program is the Streamlined Foreign Offshore (SFO) procedure, available to US citizens and certain residents who live outside the US. If you meet the 330-day non-residency requirement and your omissions were non-willful, you can catch up on all filings with a 0% offshore penalty.

That means you pay only the back taxes and interest, with no penalties on your account balances. We document your physical presence to prove eligibility and prepare the reporting needed to close your file for good.

Eligibility focus: 330-day non-residency test, non-willful behavior certification, 3-year return look-back, and 6-year FBAR look-back.

Catch-up for US residents.

Domestic Resident Benefit

Streamlined Domestic Offshore (SDO)

Catch-up for US residents.

For those living in the US who failed to report offshore accounts, the Streamlined Domestic Offshore (SDO) procedure offers a way back. It is not penalty-free, but it replaces the $10,000+ per-account penalties with a single 5% miscellaneous offshore penalty on the highest aggregate balance.

The program is only open to taxpayers who have already filed their original US income tax returns for the years in question. We model your account balances to identify the highest-balance year, calculate the 5% penalty on the most favorable basis available, and set your future reporting up correctly.

Domestic focus: Miscellaneous 5% penalty modeling, amended return preparation (Form 1040-X), and FATCA/FBAR reconciliation.

Making the case that your conduct was non-willful.

Certification Logic

The Non-Willful Standard

Making the case that your conduct was non-willful.

The most important part of a Streamlined filing is the Certification (Form 14653/14654). The IRS defines 'non-willful' as conduct due to negligence, inadvertence, or mistake, or conduct resulting from a good faith misunderstanding of the requirements of the law. If the IRS disagrees, it can reject the submission and move to a full audit.

We draft fact-based narratives that document the specific reasons for your errors, such as reliance on incorrect professional advice, lack of knowledge about US citizen-based taxation, or serious life events. This narrative is your primary defense against future IRS scrutiny.

Certification focus: Form 14653/14654, fact-based narrative drafting, reasonable cause documentation, and risk mitigation.

Behind on your US offshore filing?

The IRS Streamlined program is your way back to compliance. Don't wait for a full audit. Get a professional catch-up plan today.

What You Receive

Specific deliverables, precisely documented.

“Non-compliance is a risk. Being caught before you come forward is far worse. We prepare the certification that resolves your past omissions.”

IRS Form 14653 / 14654

The formal Certification of Non-Willful behavior, including the technical narrative of your omissions.

3 Years of Amended Returns

Full federal income tax returns (Form 1040/1040-X) including all international information forms.

6 Years of Delinquent FBARs

FinCEN 114 filings for the preceding 6 years, with the maximum balance verified on every account.

Omission Audit Report

A technical report identifying every missing account, income source, and asset reporting requirement.

5% Penalty Modeling (Domestic)

Calculations that arrive at the lowest available miscellaneous offshore penalty for US-based filers.

Residency Audit Report

Documentation of your physical presence outside the US to prove SFO (0% penalty) eligibility.

FBAR Submission Receipts

Official FinCEN confirmations of acceptance for all 6 years of your catch-up compliance reporting.

Liability & Interest Model

A forecast of the back tax and interest owed, so the cash is ready for the final submission.

Common Questions

Technical clarifications.

Answers to the most frequently asked questions about how this service works in practice.

The IRS defines it as conduct that is the result of negligence, inadvertence, or mistake, or a good faith misunderstanding of the law. In plain terms: you didn't know you had to file, or you tried and made an honest mistake.

Yes. If they believe the omissions were willful (intentional), they can reject it and move to a 'voluntary disclosure' or full audit. This is why a technically strong certification narrative is so important.

Yes. The Streamlined program eliminates penalties, but it does not eliminate the statutory interest on the tax you should have paid in the prior three years.

You are not eligible for the Streamlined program if you are already under IRS examination. That is why it matters to file voluntarily, before the IRS contacts you.

No. The IRS has closed previous amnesty programs (like OVDP) and can close the Streamlined procedures at any time. We recommend moving forward as soon as non-compliance is identified.

Contact US/UK Cross Border Tax

Two Tax Systems, One Team

London Headquarters

4 Crown Place
London EC2A 4BT
United Kingdom

Manchester

CORE
Brown St, Manchester M2 1DH
United Kingdom

San Francisco

600 California St
San Francisco, CA 94108
United States

New York

33 Irving Pl
New York, NY 10003
United States

Start a Conversation