Table of contents:
What are the Relief procedures?
The IRS offers Relief Procedures for certain former U.S. citizens/long-term residents who gave up their citizenship after March 18, 2010, and failed to meet tax filing requirements due to non-willful conduct (e.g., negligence or good-faith misunderstanding). This process allows eligible individuals to become tax compliant without penalties or interest and avoid being classified as “covered expatriates".
Relief procedures do not apply to current U.S. residents or entities (corporations, partnerships, trusts). These procedures are available indefinitely, but the IRS may announce a closing date.
For more information, refer to the IRS guide Relief procedures for certain former citizens.
Streamlined vs. Relief procedures
| Relief Procedures | Streamlined Procedures |
Purpose | Alternative path for certain non-willful ex-citizens (or soon-to-be ex-citizens) to certify six years of compliance and avoid “covered expatriate” status and the IRC § 877A exit tax. | Let current taxpayers who unintentionally failed to report foreign income/assets come into compliance with reduced or zero penalties (two tracks: Foreign Offshore and Domestic Offshore). |
Who it is for |
|
|
Returns you file | Year of expatriation plus five prior years of Forms 1040 (with all required schedules/info returns) and Form 8854; all filed together in a single package. | Three most recent years of amended/delinquent 1040s and all related information returns, plus six delinquent FBARs (FinCEN 114). |
Penalties & tax | No exit tax; late-filing, accuracy-related, and FBAR penalties waived; up to $25K of assessed income tax within the six-year window is forgiven. | Foreign track: pay tax + interest only (no penalties). Domestic track: same tax + interest plus a 5 % miscellaneous offshore penalty on the highest unreported foreign-asset value; other penalties waived. |
FBARs / information returns | Six years of FBARs or equivalent account disclosures included; FBAR penalties fully waived if you qualify. | Six delinquent FBARs required; penalty treatment follows Foreign (none) or Domestic (5 %) track. |
When you’d choose it | Ideal if you’ve renounced (or will soon), your balance sheet and back-tax exposure are modest. | Best if you remain a U.S. person, discover past foreign-asset non-compliance, and want to pre-empt an IRS exam while limiting penalties (Foreign = zero, Domestic = 5 %). |
How to file under Relief procedures
Review the eligibility criteria.
Gather all necessary documents and proof of expatriation and prepare tax filings.
Write “Relief for Certain Former Citizens” in red ink at the top of each tax return.
Include all six years in one package — no partial submissions.
Mail the complete package to the IRS address (no e-filing allowed).
Allow processing time for acknowledgement and resolution (at least two months).
After reviewing your submission to confirm that you meet the eligibility criteria, the IRS will send you a letter notifying you that your submission was received and complete.
Who qualifies
Only taxpayers whose past compliance failures were due to non-willful conduct may use these Relief procedures. You must meet all of the following:
You relinquished your U.S. citizenship after March 18, 2010.
You have never filed U.S. tax returns as a citizen or resident.
Your average annual net income tax for the 5 years ending before your date of expatriation is below $124,000.
Your net worth is less than $2,000,000 at the time of expatriation and at the time of making your submission under these procedures.
You have an aggregate total tax liability of $25,000 or less for the 5 tax years preceding expatriation and in the year of expatriation (after application of all applicable deductions, exclusions, exemptions and credits, including foreign tax credits, but excluding the application of IRC 877A and excluding any penalties and interest).
You agree to submit complete federal tax returns for all six years in question, including all required schedules and information returns.
Notes:
If you don’t qualify but still submit, the IRS will treat your returns under normal procedures and assess any taxes, penalties, and interest due.
If you are unsure whether you qualify, reach out to the Customer Success team via chat or email.
What to submit
You will need to submit the following documents under the Relief procedures:
Statement of non-willful conduct: No special form needed.
Proof of expatriation: Copy of the Certificate of Loss of Nationality(CLN, Form DS-4083) or a copy of a court order cancelling a naturalized citizen’s certificate of naturalization.
⚠ Note: The CLN must be stamped “Approved” by the Department of State.
Identification: A copy of a valid passport, birth certificate, or government-issued identification.
Tax returns:
For the year of expatriation:
Dual-status return with Form 1040NR + Form 1040 (as an information return reporting worldwide income up to date of expatriation)
Form 8854
All required information returns (e.g., Form 8938)
For the five prior years:
Complete Forms 1040 with required schedules and information returns
E-file confirmations of six FBARs (FinCEN Form 114)
Any required state tax filings
Where to mail
On the first page of each return submitted under the Relief procedures, write in red ink “Relief for Certain Former Citizens” at the top of the document.
Mail your complete package (full 6 years; do not send partial submissions) to:
Internal Revenue Service
3651 South I-H 35
Mail Stop 4301 AUSC
Attn: Relief for Certain Former Citizens
Austin, TX 78741