Streamlined Filing For US Expats

US citizens and green-card holders are taxed on worldwide income wherever they live, and most owe little or nothing thanks to the Foreign Earned Income Exclusion and Foreign Tax Credit — but they still must file, including FBAR and often Form 8938. If you've fallen behind non-willfully, the Streamlined Foreign Offshore Procedure brings you current with three years of returns and six years of FBARs, typically penalty-free. We prepare the full package and a CPA signs.

Want the full detail first? Read our complete guide to the IRS Streamlined Foreign Offshore Procedure — eligibility, the 330-day test, exactly what you must file, the penalty position, and 50 of the questions Americans in the UK ask most.

Who This Is For

The United States is one of only a small handful of countries that tax on the basis of citizenship rather than residence. That single fact catches a great many otherwise law-abiding Americans by surprise. If you hold a US passport or a green card, your filing obligation followed you onto the plane — and it does not lapse simply because you have lived in London, Dubai or anywhere else for a decade and pay tax there. The Streamlined Foreign Offshore Procedure exists precisely for people who did not realise this, or who realised it late, and want to put it right before the IRS comes looking.

The Americans abroad we most often help fall into a few recognisable situations, and each has its own anxieties:

• Accidental Americans — born in the US to foreign parents, or born abroad to an American parent — who only recently discovered they had a US filing obligation at all.
• Long-term expats who stopped filing years ago, often after an accountant told them they would owe nothing, not realising that owing nothing and filing nothing are very different things.
• Green-card holders living overseas who assumed the card was dormant while they were away, when in fact it keeps the worldwide-income obligation fully alive.
• Dual citizens with foreign bank accounts, pensions and investments who have never filed an FBAR and have only just learned the term.
• Entrepreneurs and senior employees whose foreign salary, company shares or business interests have grown large enough that the gap can no longer be ignored.

The common thread is that the failure to file was non-willful — a genuine misunderstanding, oversight or good-faith reliance on bad advice, rather than a deliberate attempt to hide income. Non-willfulness is the gateway to the programme, and it is something we assess carefully and honestly with you before recommending the route.

What The Streamlined Procedure Actually Involves

The IRS offers two streamlined tracks. The Streamlined Foreign Offshore Procedures are for taxpayers who meet a non-residency test — broadly, those genuinely living abroad — and these carry no miscellaneous offshore penalty. The Streamlined Domestic Offshore Procedures are for US-resident taxpayers and do carry a penalty. Most of our expat clients qualify for the foreign track. The official eligibility criteria and required forms are set out by the IRS on its Streamlined Filing Compliance Procedures page, and they are exacting; we work to them precisely.

A complete foreign-offshore submission has several moving parts, and an incomplete one can be rejected:

• Three years of income-tax returns — the most recent years for which the due date (with extensions) has passed, filed or amended as required, reporting worldwide income.
• Six years of FBARs — the Report of Foreign Bank and Financial Accounts (FinCEN Form 114), filed electronically through the FinCEN BSA E-Filing system for any year your aggregate foreign accounts exceeded the reporting threshold.
• The non-willful certification — Form 14653, a signed statement explaining, in your own facts, why the failure to file was non-willful. This narrative matters; the IRS reads it.
• Supporting forms — the Foreign Earned Income Exclusion (Form 2555), the Foreign Tax Credit (Form 1116), and FATCA reporting on Form 8938 where your foreign assets exceed the applicable threshold.
• PFIC and pension analysis — identifying any passive foreign investment companies and determining the correct treatment of foreign pensions before they are reported.

Because most expats are shielded by the Foreign Earned Income Exclusion and the Foreign Tax Credit, the actual US tax due across the catch-up years is frequently small or nil. The exclusion amount, the FBAR and FATCA reporting thresholds and the relevant deadlines are all set annually and can change — we confirm the current figures against IRS and FinCEN guidance before anything is prepared, and we never assume a prior year's number still holds.

Common Mistakes We Are Asked To Fix

Most of the difficult cases we untangle began as small misunderstandings that compounded quietly over the years. None of them are unusual; all of them are manageable when caught.

• Assuming "I owe nothing, so I needn't file." The filing obligation is independent of the tax due. Non-filing is what creates exposure, not the balance owed.
• Filing through the regular system instead of Streamlined, which forfeits the penalty protection the programme is designed to provide.
• Forgetting the FBAR entirely — many people file income-tax returns but never report their foreign accounts, where the most serious penalties historically lived.
• Holding foreign mutual funds and ETFs without realising they are PFICs, which carry punitive treatment and complex reporting if left unaddressed.
• Writing a thin or careless non-willful statement that fails to tell a coherent, truthful story — the single most common reason a submission draws follow-up questions.
• Doing nothing once a bank sends a FATCA letter, when a quiet, proactive Streamlined filing is almost always the stronger position.

How Next Tax Source Handles It

Our model pairs an always-on team of specialist AI agents with licensed human review. The agents reconstruct your income across the catch-up years, optimise the Foreign Earned Income Exclusion and Foreign Tax Credit together so you are not double-taxed, prepare each return and FBAR with full workpapers, and draft a careful non-willful certification grounded in your actual facts. A US CPA or Enrolled Agent then reviews and signs the package before it goes anywhere.

Crucially, we prepare everything to a ready-to-sign standard — you, the taxpayer, sign and submit your own return and FBARs. We never file to the IRS on your behalf, and nothing leaves on AI output alone. We also give you a plain, signed memo on staying compliant going forward, so this is the last time you ever fall behind. If you also have obligations in the UK or UAE, our cross-border specialists coordinate the whole picture. You can book a private consultation to talk it through, or review our pricing first.

What To Prepare

A first conversation moves faster if you can gather the basics. None of it needs to be tidy — most of our engagements begin precisely because it is not.

• Your US tax filing history, as best you know it, and the last year you filed
• Foreign income records — payslips, self-employment or business accounts, rental income
• Statements for all foreign bank, investment and pension accounts for the relevant years
• Details of any foreign mutual funds, ETFs or company shareholdings
• Any local tax returns you have filed in your country of residence
• Any correspondence you have received from a bank or from the IRS, including FATCA letters

You can also model your likely US position first with our calculators, and read more expat-focused guidance in our journal, before you speak to us.

Your Next Step

Coming forward voluntarily, before the IRS contacts you, is what makes the Streamlined Procedure available — once you are under examination, the door to the programme can close. If you have been putting this off, the most valuable thing you can do is start the conversation. We will tell you honestly whether you qualify, what the realistic outcome looks like, and what it will cost, before you commit to anything.

Questions People Ask