Behind on US taxes while living abroad? Catch up safely with the streamlined filing compliance procedures.
Many Americans in the UK only find out about US filing years later. The IRS streamlined filing compliance procedures, including the streamlined foreign offshore procedure, exist for people in exactly that position. Our IRS Enrolled Agents help you check if you qualify and catch up the right way.
What the streamlined procedures are
The streamlined foreign offshore procedure, in plain English.
The streamlined filing compliance procedures are an IRS route for US taxpayers who missed returns or FBARs without meaning to. The IRS calls this “non-willful”: for example, you did not know the rules applied to you.
For people living outside the US, the version is called the streamlined foreign offshore procedure. In general terms, you file the last 3 years of US tax returns and the last 6 years of FBARs, and certify that the failure was non-willful.
Whether it fits depends on your facts. That is the first thing we check, before anything is filed.
Filing missing forms on your own, without the right certification, can leave things worse, not better. Talk to us before you file anything.
Before and after
Before and after the streamlined filing compliance procedures
Before: years of missed US returns and FBARs
- You have just found out you should have been filing
- Worry about FBAR penalties for UK bank accounts
- Your bank is asking about your US tax status
- Not sure whether to file quietly or come forward
After: back in the IRS system, with a plan
- Eligibility for the streamlined procedures checked first
- Missing returns and FBARs prepared and filed
- Your non-willful certification written carefully
- Annual filing set up so it does not happen again
Late filers and streamlined help
Streamlined filing compliance procedures help, from start to finish.
Streamlined foreign offshore procedure
For US taxpayers living outside the US: the last 3 years of returns and 6 years of FBARs, filed together.
Delinquent FBAR and Form 8938
Missing reports for UK bank accounts, ISAs, pensions and other foreign assets.
FBAR penalty worries
We explain your options plainly and the strategies used to reduce penalty risk.
Voluntary disclosure guidance
If streamlined is not the right route, we explain the other IRS options.
UK side covered too
Including the UK Worldwide Disclosure Facility for offshore income, if needed.
Staying compliant
Once you are caught up, we file every year so you stay that way.
How it works
How the streamlined filing compliance procedures work with us.
- Step
Confidential review
We look at your history, your accounts and why filing was missed.
- Step
Check eligibility
We confirm whether the streamlined foreign offshore procedure fits, or another route is better.
- Step
Prepare the catch-up
Missing returns, FBARs and the non-willful certification, prepared together.
- Step
File and stay current
We submit, then keep you compliant each year.
Who you will work with
Streamlined procedures led by IRS Enrolled Agents.
Tas Meghani has significant experience helping delinquent taxpayers get back into the IRS system under the IRS amnesty programmes.
Tas Meghani
Tax Director, Head of Trusts & Estates, London
20 years of US and US/UK tax experience, previously with EY Frank Hirth, Buzzacott and PwC. Significant experience helping individuals expatriate from the US, and helping delinquent taxpayers get back into the IRS system under the IRS amnesty programmes. IRS Enrolled Agent, LL.M in Taxation (UCL).
Glenn Snow
US/UK Tax Director, Private Client Group, London
Dual-qualified tax adviser with over 16 years advising individuals on US and US/UK tax. Joined from EY Frank Hirth, where he worked in London and New York. IRS Enrolled Agent and member of the Association of Taxation Technicians (ATT).
Spear’s 500 Recommended Advisor. Shortlisted, Citywealth Accountant of the Year 2020.
Patricia Lydon
US Tax Director, Private Client Group, London
Part of the London Private Client Group, working on US tax returns, compliance and expatriation for US-connected individuals.
Andrew Aldridge
Tax Director & US Attorney, London
Over 40 years of domestic and international tax experience, including five years in the UK as Tax Counsel for Phillips Petroleum. Assists US taxpayers who wish to give up US citizenship while minimising the impact of the Exit Tax. Licensed attorney, Oklahoma.
Offices
Streamlined filing help from our London office.
Meet our team in London, or call us wherever you live.
London WC1V 7QH
+44 20 7357 8220
CH 8004 Zurich
+41 44 387 8070
CH 1205 Geneva
+41 22 700 2500
Questions
Streamlined filing compliance procedures: common questions.
What are the streamlined filing compliance procedures?
An IRS route for US taxpayers who did not file returns or FBARs, where the failure was non-willful. The version for people living abroad is the streamlined foreign offshore procedure.
What do I have to file?
In general, the last 3 years of US tax returns and the last 6 years of FBARs, plus a certification that the failure was non-willful. We confirm the exact list for your case.
Do I qualify for the streamlined foreign offshore procedure?
It depends on where you lived, why filing was missed and what you held. We check that first, before anything is filed.
What is an FBAR?
FinCEN Form 114, the report of foreign bank and financial accounts. US persons generally file one if their non-US accounts added up to more than $10,000 at any time in the year.
Can you promise there will be no penalty?
No one honestly can. We explain your options and the risks plainly, and use the route that best fits your facts.
I also want to give up US citizenship. Does this come first?
Usually yes. See our page on renouncing US citizenship and the tax side.
Confidential introductory call
Talk to us about the streamlined procedures before you file.
Tell us briefly what was missed. An IRS Enrolled Agent will arrange a confidential introductory call.
London office, Staple Court, 11 Staple Inn, WC1V 7QH.
- Confidential from the first call
- IRS Enrolled Agents in London
- US and UK sides handled together