Haven't Filed US Taxes in Years? The IRS Has a Penalty-Free Solution.

The Streamlined Filing Compliance Procedures are a formal IRS amnesty program introduced in 2014 for non-willful delinquent filers. Qualifying US expats can file 3 years of back tax returns and 6 years of FBARs with all failure-to-file, failure-to-pay, and FBAR penalties completely waived. You pay only the tax owed plus statutory interest. There are two tracks: SFOP (for expats living abroad) and SDOP (for US residents with foreign accounts).

Non-willful means you did not deliberately conceal income or accounts from the IRS. Courts have consistently found that non-willful conduct includes: not knowing the US taxes citizens living abroad, misunderstanding FBAR rules, relying on an accountant who gave incorrect advice, or simply neglecting to file due to the demands of relocating abroad. The vast majority of expats who haven't filed qualify as non-willful. If your non-filing was deliberate income concealment, you do not qualify and should consider voluntary disclosure instead — contact Mark to discuss.

Under SFOP, you file 3 years of Form 1040 federal tax returns and 6 years of FBARs. The 3-year period is the most recent 3 years for which the IRS filing deadline has passed. The 6-year FBAR period covers the 6 most recent calendar years. You do not need to file every missed year going back further — only the years specified in the program.

You owe any tax that was legally due on your returns, plus interest. Penalties are waived — not the underlying tax. However, many expats owe little or no additional tax because the Foreign Earned Income Exclusion (up to $130,000 for 2025) eliminates most income tax on foreign-earned wages. Mark calculates your exact tax owed as part of return preparation — there are rarely any surprises by the time you sign.

Yes — and this is one of Streamlined's greatest benefits. FBAR filing for 6 years is built directly into the SFOP package. Normally, FBAR penalties start at $10,000 per year per account for non-willful failure — and those penalties are completely waived under SFOP. If you have multiple accounts, the savings can be enormous.

Form 5471 (required for US persons who own 10%+ of a foreign corporation) is not automatically included in the standard Streamlined package, but it can be filed alongside it. The $10,000 automatic penalty per missed Form 5471 may also be waived under the non-willful certification. Mark prepares all required forms — this adds complexity but does not disqualify you from the program.

Streamlined Filing does not automatically trigger an audit. In practice, the IRS processes the vast majority of Streamlined submissions without further inquiry. However, the IRS retains the right to examine any return filed under Streamlined — which is exactly why accuracy in the returns and the Form 14653 narrative is critical. A submission prepared carefully by an experienced expat CPA significantly reduces audit risk.

Most Streamlined cases are completed in 8–12 weeks from the initial consultation to filing, depending on document availability. The IRS typically processes Streamlined filings within 6–12 months. You don't need to do anything after filing — if the IRS has follow-up questions, Mark handles all correspondence.

There is no published expiration date for the Streamlined program, but two things can end your eligibility: (1) the IRS can close or modify the program at any time without advance notice, and (2) if the IRS contacts you first about an examination or criminal matter, you are no longer eligible. Both of these are strong reasons to act now rather than wait.

It depends on the type of contact. A CP2000 notice or balance-due letter about a specific year is NOT the same as an examination opening — you may still be eligible. However, if the IRS has formally opened an audit (civil examination) of your returns or begun a criminal investigation, Streamlined is no longer available. In those cases, penalty abatement or other resolution paths may apply. Contact Mark immediately — the sooner you act, the more options you have.