Streamlined filing: getting current, penalty-free on the Foreign Offshore route.
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.
One fixed fee covers the entire package — every return, every FBAR, the certification and the submission — with one specialist 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
- Confirm the route is the right oneEstablish 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 appliesLiving 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 yearsGather 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 FBARs3 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 certificationA 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 forwardThe 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.
What the fixed fee includes
- Eligibility review before anything is filed
- Three years of returns, prepared or amended
- Six years of FBARs
- Form 14653 certification, drafted with you
- Foreign tax credits applied to minimise tax due
- PFIC and information forms the years require
- Single fixed fee for the whole package
- Forward plan so you stay current after
How the engagement runs
Often handled together
Questions we get about this
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 taking advice on 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 pages
- Service
Pensions & retirement
Cross-border pension advice: UK pensions under US rules, 401(k)s and IRAs under UK rules, lump sums and treaty positions.
- Glossary
Streamlined Procedures: definition
The catch-up route: 3 years of returns, 6 of FBARs, one certification — penalty-free 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.
- Pillar guide
Accountants for US and UK
How to choose accountants for US and UK tax: what each credential permits, how to verify it, what drives the fee, and when you do not need a specialist.
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.
- Delinquent FBAR procedures: three ways back to compliance
Missed FBARs rarely stay missed. Here are the three routes back, what each one costs, and how to pick the right one before the IRS picks for you.
Last reviewed . Thresholds and rates change annually — check figures against the current tax year before relying on them.
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 quote a single fixed fee for all of it.