Streamlined Foreign Offshore Procedures.
The IRS route back for Americans abroad who didn't know they had to file: three years of returns, six years of FBARs, a sworn statement that the failure was non-willful — and, on the Foreign route, no penalties.
A route back with a deadline you can't see
Streamlined is only open before the IRS contacts you, and FATCA means UK banks are already reporting US-person accounts. The certification on Form 14653 is the heart of the package — a factual narrative of why you didn't file, signed under penalty of perjury, worth drafting with care.
- Foreign route: no US abode and 330 days abroad in one of the last three years
- All penalties waived on the Foreign route; the Domestic route charges 5% of the highest aggregate value
- Most submissions owe little or nothing in actual tax
What goes in the package
The IRS asks for the most recent 3 years of returns whose due dates have passed and the most recent 6 years of FBARs. Any tax shown is paid with statutory interest. Each return is marked "Streamlined Foreign Offshore" at the top, and the package is posted on paper; the IRS does not accept it electronically.
Every return needs a valid taxpayer number, which for a citizen means a Social Security number. Getting one from Britain takes weeks, so it comes first.
| Foreign Offshore | Domestic Offshore | |
|---|---|---|
| Who it is for | People meeting the non-residency test | People living in the United States |
| Certification | Form 14653 | Form 14654 |
| Penalty | None for qualifying filers | 5% of the highest aggregate account value |
| Returns and FBARs | 3 returns, 6 FBARs | Amended returns plus FBARs |
Non-willful is the test that matters
The IRS describes non-willful conduct as negligence, inadvertence, mistake, or a good faith misunderstanding of the law. The certification must explain your facts in your own words: when you learned of the obligation and what you did next.
Generic wording that repeats the definition persuades nobody. Specific, truthful detail is what carries the submission.
Questions we get about this
On the Foreign Offshore route, for people who qualify and comply fully, the IRS says it will not impose failure-to-file, failure-to-pay, accuracy, information return or FBAR penalties. The Domestic route is different and charges 5% of the highest aggregate account value.
Under the Foreign route, the three most recent tax returns whose due dates have passed and the six most recent FBARs. Earlier years are generally not required under the procedure.
Generally no. The procedures are for taxpayers who come forward before the IRS has started an examination or other contact about the relevant years. That is why acting early matters.
Yes. The IRS requires a valid taxpayer number on every Streamlined return, and for a US citizen that means a Social Security number. From Britain, adults apply through the US Embassy in London and should allow two to three months.
Related pages
- Glossary
Substantial Presence Test: definition
The day-count formula that makes visitors into US tax residents.
- Service
Streamlined catch-up filing
Streamlined Foreign Offshore Procedures: 3 years of returns, 6 years of FBARs and the non-wilful certification, with no penalty on the Foreign route.
- Free tool
Streamlined eligibility checker
Free checker: answer six questions to see whether the Streamlined Foreign or Domestic Offshore route fits your catch-up - and what each would cost.
- Service
FBAR & FATCA reporting
FBAR (FinCEN 114) and FATCA (Form 8938) preparation: thresholds checked, accounts aggregated, and both reports filed alongside the return they belong to.
- Pillar guide
Tax specialists for US and UK
What US and UK tax specialists handle that a general accountant does not: residence tests, treaty relief, FBAR, PFICs, pensions, property and catch-up filings.
- Glossary
FBAR: definition
The Foreign Bank Account Report — FinCEN Form 114 — and its $10,000 aggregate trigger.
Further reading
- Streamlined filing: getting current, penalty-free on the Foreign Offshore route
The route back for people who did not know they had to file. Narrower than it looks, and worth assessing before you submit anything.
- Streamlined filing cost: the three numbers that decide it
What does a streamlined catch-up actually cost? Three numbers decide it - and the biggest one is often zero for expats. Here is the honest breakdown.
- The foreign housing exclusion: two numbers people keep confusing
Rent in London is high enough that the foreign housing exclusion is worth claiming. It is also worth understanding, because the ceiling on qualifying expenses and the amount you can actually exclude are different numbers.
Last reviewed . Thresholds and rates change annually — check figures against the current tax year before relying on them.
Years behind?
This is the route back. One fixed fee covers the whole package.