Which years should I file for if I’m using a Streamlined Procedure?

The Streamlined Foreign Offshore Procedures require 3 tax returns + 6 FBARs.

The Streamlined Foreign Offshore Procedures stipulate that you must file your 3 most recent delinquent tax returns, including extensions. At the time of writing (July 16, 2020), you should file returns for 2017, 2018, and 2019.

Why not 2018, 2019, and 2020? Because your 2020 tax return is not yet overdue. Assuming the program does not change, 2020 returns will become overdue (for those abroad) on July 15, 2021.

The IRS has also issued guidance on how to file extensions for those who are behind on their returns. 

*Source -  IRS.

When are FBARs due?

The due date for a FBAR return is April 15 of the following calendar year. So, the due date for 2019 FBARs is April 15, 2020. However, the Treasury is currently granting an automatic 6-month extension for FBARs making the new due date October 15, 2020.

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