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CATCHING UP

Behind on US filings? There is an IRS route.

If you meet the IRS's non-residency test and missed US returns or FBARs through non-willful conduct, the IRS Streamlined Foreign Offshore Procedures are the IRS's own way to catch up. Here is who the IRS says can use them, what is filed, and the terms, from the IRS's pages.

See who can use it

Reviewed 22 October 2026. A description of an IRS program, not an eligibility decision.

Man sorting older papers from a box into neat piles at a sunny kitchen table
WHAT IT IS

An IRS program, on the IRS's terms.

The procedures are for taxpayers who certify that their failure to report foreign financial assets and pay tax on the income from them was due to non-willful conduct. The IRS decides eligibility and outcomes; no preparer can promise a result.

THE CORE TEST

Non-willful conduct

The IRS describes it as conduct due to negligence, inadvertence or mistake, or "a good faith misunderstanding of the requirements of the law".

You certify that your conduct was not willful.

WHO

Individuals only

The procedures are designed only for individual taxpayers, including estates of individual taxpayers.

WHERE

Non-US residents, as the IRS tests it

The foreign offshore procedures are for non-US residents. The IRS has a separate streamlined track for US residents, not described here.

WHO CAN USE IT

The IRS's tests, in its own words.

The non-residency test looks at the most recent three years whose return due date has passed. Meeting it in any one or more of those years is enough.

Non-residency test for the Streamlined Foreign Offshore Procedures
You areThe IRS test, in at least one of the three years
A US citizen or green card holderYou did not have a US abode and were physically outside the United States for at least 330 full days.
Anyone elseYou did not meet the substantial presence test of IRC section 7701(b)(3).

When the IRS says the procedures are not available

  • An IRS civil examination has startedOf your returns for any taxable year, whether or not it involves foreign assets.
  • You are under criminal investigation by IRS Criminal Investigation
  • You submitted an OVDP letter on or after July 1, 2014
WHAT IS FILED

Four parts, one package.

The IRS instructions, step by step. The years move as due dates pass, so check them on the day you start.

  1. 1

    Three years of returns

    For each of the most recent 3 years whose US return due date has passed: a delinquent Form 1040 for a year with no return, or an amended Form 1040-X for a year already filed, together with all required information returns.

  2. 2

    Six years of FBARs, filed electronically

    Any delinquent FBARs (FinCEN Form 114, previously Form TD F 90-22.1) for each of the most recent 6 years whose FBAR due date has passed. They go electronically through FinCEN's BSA E-Filing System, not in the mail with the returns. On the cover page the IRS says to select "Other" as the late-filing reason and enter "Streamlined Filing Compliance Procedures". About the FBAR
  3. 3

    The certification, Form 14653

    The signed "Certification by U.S. Person Residing Outside of the U.S." states that you are eligible, that all required FBARs have been filed, and that the failures resulted from non-willful conduct. The original signed statement is submitted; copies go with each tax return and each information return, never with the FBARs.

  4. 4

    Marked in red, mailed on paper with payment

    Write "Streamlined Foreign Offshore" in red at the top of the first page of each return and each information return. Returns and payment of the tax and interest go to the IRS on paper; the IRS does not accept electronic submissions for these filings.

IRS MAILING ADDRESS FOR THESE FILINGS ONLY

Internal Revenue Service
3651 South I-H 35, Stop 6063 AUSC
Attn: Streamlined Foreign Offshore
Austin, TX 78741
The expat filing calendar Documents to gather
THE IRS'S TERMS

What the IRS says, and its limits.

An eligible taxpayer who complies with the instructions "will not be subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties, or FBAR penalties."

IRS, Streamlined Foreign Offshore Procedures
  • Tax and interest are still paidThe full amount of tax and applicable statutory interest due on the filings must be paid with the submission.
  • Earlier penalties stayPenalties already assessed for those years are not abated.
  • The statement must be completeWithout the statement, or with an incomplete or deficient one, or without following the instructions, the returns are processed in the normal course without the favorable terms.
  • After an auditThe terms continue unless the examination finds the original noncompliance was fraudulent or the FBAR violation was willful. If the IRS finds an additional tax deficiency, it may assert the additions to tax and penalties related to it.
WHAT EXPATRETURN.US CAN PREPARE

A guided package, mailed by you.

The software can prepare the streamlined package for a customer whose answers pass the checks below, in this order. The returns and certification are mailed by you on paper to the IRS in Austin, Texas. The FBAR file is uploaded to FinCEN's BSA E-Filing System by our team.

  1. 1

    Eligibility first

    Your answers are checked against the IRS non-residency test before anything is created.

  2. 2

    Three returns, in sequence

    Delinquent returns for the three window years, one after the other.

  3. 3

    The earlier FBAR years

    The six FBAR years, prepared together as one file for FinCEN. FBARs come first, because Form 14653 certifies they have been filed.

  4. 4

    Certification and summary

    A preparation sheet for Form 14653 and a summary of what goes to FinCEN and what is mailed to the IRS.

What the package contains

  • The three delinquent returnsFor the three most recent window years as of the day you start. If the years move mid-way, you are asked to start again for the new years.
  • Six FBAR years as one filePrepared from your answers, then checked and uploaded to FinCEN's BSA E-Filing System by a person on our team, with each Form 114a typed by you. There is no automatic transmission. Each report past October 15 carries "Other" and "Streamlined Filing Compliance Procedures".
  • A Form 14653 preparation sheetIt carries every certification value. The IRS's blank form cannot be filled by software, so you copy the values into the official form before mailing.
  • Cover statement, checklist and addressWith the red-ink instruction for the top of each return and the IRS mailing address.
  • A signal to mailOnce FinCEN accepts the FBAR file, our team tells you to sign and mail the paper submission.

Limits to know

  • Delinquent returns onlyA window year you have already filed is refused; this package does not prepare amended returns.
  • Citizens and green card holdersThe software does not compute the substantial presence test. On a joint submission, your spouse must also meet the 330-day and no-abode test.
  • Your statement, your certificationThe narrative starts with one sentence per reason you choose; you edit and confirm it. The software gives no advice on whether your conduct was non-willful.
  • Only some IRS conditions are askedIt asks whether you are under IRS examination and requires a valid SSN or ITIN. It does not ask about the other IRS conditions above; those remain yours to check with the IRS.
  • One FBAR per person and yearIf another return in your account already released an FBAR for the same person and year, the package's FBAR file is not released until FinCEN's answer to that report is recorded, and a correction of it is filed as an amendment.
  • Funds agree from year to yearA fund reported on Form 8621 carries the earlier years' figures into the later years, and the years must agree: the same choices, the same purchase days, and no fund you still held left off. Otherwise the package is refused by name.

Price, by plan tier

The streamlined package is prepared separately, not in the plan price. Each price covers the three past returns and the FBARs, for returns within the scope of the matching plan.

STANDARD

$699

For a salary abroad, bank interest, and ordinary dividends.

PREMIER

$819

For freelancers and independent contractors: one business for you, and one for your spouse.

INVESTOR

$939

For investment sales and rental or royalty income alongside your other income.

QUESTIONS

Common questions, calmly answered.

All questions
Does using the procedures mean I owe no penalties at all?

The IRS's words are that an eligible taxpayer who follows the instructions "will not be subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties, or FBAR penalties." The tax and statutory interest are still paid, penalties already assessed for those years are not abated, and the limits described above apply.

I already filed one of the three years. Can ExpatReturn.us still prepare my package?

No. The IRS route allows an amended Form 1040-X for a year already filed, but this package prepares delinquent returns only, so a window year that has already been filed is refused by name.

I made a quiet filing in the past. Does that rule me out?

The IRS says earlier quiet filings made outside the OVDP do not bar use of the procedures, but penalties already assessed on them are not abated. For anything more, read the IRS overview (opens in a new tab).

What if I live in the United States?

The IRS has separate streamlined procedures for US residents. This page describes only the foreign offshore procedures. If you do not meet the non-residency test, start from the IRS overview linked below.

Where can I read about narratives, joint returns or a missing SSN?

The IRS FAQ page for these procedures covers what the Form 14653 narrative should include, filing a joint amended return when a spouse will not sign, correcting a mistake in an earlier streamlined submission, and submitting without a Social Security number.

What does the streamlined package cost?

It is priced by plan tier and prepared separately, not in the plan price: $699 (Standard), $819 (Premier) or $939 (Investor). Each price covers the three past returns and the FBARs. You pay before the package is produced, and you mail it to the IRS yourself.

Official sources

Last reviewed 22 October 2026

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ONE STEP AT A TIME

Know your dates before you begin.

The streamlined window follows due dates. Our guide to expat filing dates and extensions is a calm place to start.

See the filing calendar