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Streamlined Filing Procedures

Streamlined Offshore Filing Procedures

If you are a U.S. taxpayer who did not report foreign income, accounts, assets, or entities, and the failure was non-willful, the IRS streamlined filing compliance procedures may be a way to come into compliance. A licensed CPA reviews your history and prepares the required submission.

Introductory consultation. Eligibility is assessed only after a review of your facts.
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When It Applies

Who These Procedures Are For

The streamlined procedures are intended for qualifying taxpayers whose failure to report was non-willful.

Unreported foreign accounts

Bank or investment accounts abroad that were never reported on an FBAR or Form 8938.

Unreported foreign income

Foreign wages, self-employment, rental, pension, or investment income left off U.S. returns.

Missed international forms

Foreign entities, gifts, or trusts that should have been reported on forms such as 5471, 3520, or 8865.

You want to get current the right way

You would rather come forward correctly than wait for the IRS to make contact.

Two Procedures

Domestic and Foreign Procedures

Streamlined Foreign Offshore Procedures

For taxpayers who meet the non-residency requirement. Where eligibility is met, the offshore penalty is generally waived, though tax and interest apply.

Streamlined Domestic Offshore Procedures

For eligible taxpayers residing in the U.S. A separate miscellaneous offshore penalty generally applies under this procedure.

Important Boundaries

Eligibility and Non-Willfulness

Eligibility is not automatic and cannot be confirmed before your facts are reviewed. The procedures require that the failure to file was non-willful, and a non-willfulness certification is part of the submission. Where the facts suggest possible willfulness, criminal exposure, or a need for legal privilege, the right step may be a referral to a qualified tax attorney rather than a streamlined submission. We do not treat willfulness casually and do not market these procedures as automatic penalty elimination.

What Is Included

What a Streamlined Submission Involves

Returns and FBARs

Three years of required income-tax returns or amended returns where applicable, and six years of FBARs where applicable.

International forms

Coordination of international information returns and foreign tax credits within the submission.

Certification and assembly

Support with the non-willfulness certification, submission assembly, and post-submission questions or notices within scope.

Transparent Pricing

Streamlined Offshore Pricing

The final fee is confirmed in writing after a review of your facts.

Streamlined Offshore Procedures

Starting at $4,000

The fee depends on whether the domestic or foreign procedure applies, the number of returns and FBARs, the number of accounts, foreign entities, forms such as 3520, 3520-A, 5471, 8865, or 8621, the quality of your records, whether amended returns are needed, and the complexity of the non-willfulness certification.

What is separately scoped

Extensive bookkeeping cleanup, prior-year reconstruction beyond the submission, and matters requiring legal counsel are handled separately. Your written proposal states what is included.

How It Works

The Process

1

Review your history

We look at your residency, unfiled or amended years, foreign accounts, and any foreign entities, and assess whether a streamlined submission fits.

2

Confirm scope and fee

You receive a written scope and flat fee before preparation begins, including whether an attorney referral is appropriate.

3

Prepare and submit

We prepare the returns, FBARs, and certification, assemble the submission, and support post-submission questions within scope.

Clarifications

Streamlined Filing Questions, Answered

What is the difference between the domestic and foreign procedures?
The foreign procedure is for taxpayers who meet the non-residency requirement and generally waives the offshore penalty. The domestic procedure is for eligible U.S. residents and generally applies a miscellaneous offshore penalty. Tax and interest apply under both.
What does non-willful mean?
In general terms, it refers to conduct due to negligence, inadvertence, mistake, or a good-faith misunderstanding of the law, rather than an intentional choice not to comply. Whether your facts meet that standard is assessed carefully, and it is not a conclusion we ask you to reach on your own.
How many returns and FBARs are involved?
The procedures generally involve three years of income-tax returns or amended returns where applicable and six years of FBARs where applicable, though the exact scope depends on your facts.
Can eligibility be confirmed during the free call?
The introductory call confirms whether the matter fits our services and the appropriate next step. Assessing eligibility and non-willfulness requires a review of your facts, which may be a paid engagement.
When might an attorney be involved?
If the facts suggest possible willfulness, criminal exposure, or a need for legal privilege, we may recommend a qualified tax attorney rather than a streamlined submission.

Discuss Your Offshore Filing History

Tell us about your residency, the years involved, and your foreign accounts or entities. We will confirm whether it fits our services and the appropriate next step.