Streamlined offshore procedures
If you did not know foreign accounts had to be reported, there is a formal route back into compliance — and it is far better than being found.
You are in the right place if…
Unreported foreign accounts
Any number of years where an FBAR should have been filed.
Unreported foreign income
Interest, rent or gains from abroad that never reached a U.S. return.
Recently discovered the rule
Most people find out from a colleague, not from the IRS.
Everything in the fee
- Eligibility assessmentReview
- Amended returns for the required years1040-X
- Delinquent FBAR filingFinCEN 114
- Non-wilful conduct certification14653 / 14654
- Foreign tax credit recalculation1116
- Penalty exposure analysisAdvisory
What the programme is for
The IRS Streamlined Filing Compliance Procedures exist for taxpayers whose failure to report foreign accounts and income was non-wilful — that is, the result of not knowing, misunderstanding, or negligence rather than a deliberate decision to conceal. Most people in that position genuinely had no idea an ordinary savings account back home was reportable.
Why acting first matters so much
The programme is only available to people who come forward before the IRS contacts them about it. Once an examination has started, this route closes and the remaining options are markedly worse. Financial institutions abroad now report account holder information to the U.S. under FATCA, so the discovery risk is not theoretical.
What the process involves
Amended returns for the required look-back period, delinquent FBARs for a longer period, and a signed certification explaining why the failure was non-wilful. That certification is the part that matters most — it is a statement made under penalty of perjury, and it needs to be accurate and complete rather than optimistic.
This is a judgement call, not a form
Whether you qualify, which programme fits, and how the certification is written all turn on your specific facts. Talk to us before filing anything — including before filing a late FBAR on its own, which can foreclose better options.