IRS Streamlined Filing Compliance Procedures
The IRS Streamlined Foreign Offshore Procedures are a formal compliance programme designed for US citizens and green card holders who lived abroad and failed to file US tax returns or FBARs. If your failure to comply was non-wilful (due to misunderstanding or ignorance rather than deliberate evasion), you may be eligible to come fully compliant with penalties waived. Time is critical: eligibility ends the moment the IRS contacts you.
Get started with your filingWho this is for
- ✓ US citizens or green card holders who lived outside the US for at least one of the past three years
- ✓ Those who did not file US tax returns or FBARs and whose non-compliance was non-wilful
- ✓ Expats who filed incorrectly (missed FEIE, FTC, or FBAR) and qualify as non-wilful errors
- ✓ Anyone coming forward voluntarily before the IRS has initiated an examination
What this filing may involve
Every situation is different. The forms below commonly apply — your specific filing may vary.
- 1 3 years of Form 1040 (delinquent or amended) for the most recently due tax years
- 2 6 years of FinCEN Form 114 (FBAR) filed through the BSA E-Filing System
- 3 Form 2555 — FEIE elections applied for qualifying years
- 4 Form 1116 — Foreign Tax Credit applied for qualifying years
- 5 Non-wilful certification statement signed by the taxpayer under penalties of perjury
- 6 Payment of any taxes owed plus interest (no penalties under Streamlined)
Documents usually needed
- 📄 Income records for the past 3 tax years (pay slips, 1099s, self-employment ledgers)
- 📄 Records of foreign taxes paid for each year
- 📄 Foreign bank account statements showing maximum balances for each of the past 6 years
- 📄 Travel records establishing physical presence outside the US
- 📄 Any prior US tax returns or correspondence with the IRS
How Nomadic.Tax works
AI-assisted preparation with licensed professional review — every time.
We assess your eligibility for the Streamlined Foreign Offshore Procedure
Our team prepares 3 years of returns, applying FEIE and FTC to minimise liability
We prepare all 6 years of FBARs and assist you in drafting the non-wilful certification
A licensed CPA reviews the complete package before submission to ensure compliance
When human review matters
- ⓘ The non-wilful certification is a serious legal statement — it must be truthful and complete
- ⓘ If your non-compliance could be characterised as wilful (deliberate concealment), the Streamlined Procedure may not be appropriate
- ⓘ The procedure must be completed before the IRS contacts you — acting promptly is essential
Deeper reading on NomadIcTax.org, our educational resource site
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Relevant plans
Choose the package that best fits your situation, or view all plans.
- ✓ Up to 6 years of FBAR
- ✓ Prepared for streamlined compliance
- ✓ Includes self-employment and platform income
Frequently asked questions about IRS Streamlined Filing Compliance Procedures
What does 'non-wilful' mean in the context of Streamlined?
Non-wilful means your failure to file was due to negligence, inadvertence, misunderstanding, or a good-faith misunderstanding of US law — not deliberate tax evasion. Most expats who simply didn't know about US filing requirements qualify as non-wilful.
Are all penalties truly waived?
Under the Streamlined Foreign Offshore Procedure, failure-to-file penalties, failure-to-pay penalties, and FBAR penalties are waived. You pay only the tax owed (if any) plus interest. This is the key benefit compared to standard delinquent filing.
Can I use the Streamlined Procedure if I'm now back in the US?
There's a separate Streamlined Domestic Offshore Procedure for US residents, which carries a 5% miscellaneous offshore penalty rather than the full waiver. If you've recently returned to the US, timing matters — eligibility under the foreign procedure requires having lived abroad for at least one of the past three years.
How long does the Streamlined filing process take?
Typically 4–8 weeks to prepare, depending on the complexity of your returns and how quickly we receive your documents. IRS processing times after submission vary but are typically several months.