If you are not up to date on your U.S. tax returns and/or FBARs, the IRS offers an amnesty program called the Streamlined filing compliance procedures (Streamlined procedures or SP). This program is designed for U.S. taxpayers whose non-compliance was non-willful — meaning the failure to file was due to oversight, misunderstanding, or negligence, not an intentional attempt to evade taxes.
Under the Streamlined filing compliance procedures, you must file:
3 most recent delinquent tax years (regardless of how many years you have actually missed), and
6 most recent delinquent FBAR years.
The major benefit of joining the Streamlined procedures is that most scary IRS penalties for failure to declare foreign bank accounts (FBAR penalties) and related penalties are waived.
Questions you might have when deciding on whether to join the Streamlined procedures program
1. Am I eligible to apply for the Streamlined procedures?
1. Am I eligible to apply for the Streamlined procedures?
There are two versions of this amnesty program:
Streamlined foreign offshore procedures (SFOP) – for taxpayers living outside the U.S.
Streamlined domestic offshore procedures (SDOP) – for taxpayers living in the U.S.
The main disqualifier is willfulness. You generally do not qualify if you:
Knew you were required to file, and
Intentionally chose not to file.
2. If I file under Streamlined procedures with TFX, does it mean that I am automatically accepted to the program?
2. If I file under Streamlined procedures with TFX, does it mean that I am automatically accepted to the program?
We assess your eligibility and determine which program is best for you based on your Tax Questionnaire and documents. If we think that you would not qualify, we will advise on alternate filing routes. Please bear in mind that the program is an application for amnesty. While there is no guarantee that you will be accepted into the program, the TFX team has a lot of experience filing under the Streamlined procedures. We closely comply with the IRS requirements. Therefore, our success rate is excellent.
3. Can I use Streamlined procedures if I live in the U.S.?
3. Can I use Streamlined procedures if I live in the U.S.?
Yes. If you do not meet the foreign residency test (having lived at least one year abroad out of the last three), you may file under the Streamlined domestic offshore procedures (SDOP). Refer to the IRS help article U.S. taxpayers residing in the United States for more information.
4. What if I don’t qualify for Streamlined procedures? What are the other options?
4. What if I don’t qualify for Streamlined procedures? What are the other options?
Your options depend on your situation:
Willful non-compliance → You may need the Voluntary Disclosure Practice (VDP) (higher penalties, but reduced risk of criminal charges).
You are a former U.S. citizen/long-term resident and non-willfully failed to file U.S. tax returns → You may use the Relief procedures for former US citizens IRS amnesty program.
You have not filed information forms, e.g., Form 5471 for foreign corporations; Forms 3520/3520-A for foreign trusts and foreign gifts; Forms 8938 (FATCA) → You may use the Delinquent international information return submission procedures with a strong, reasonable-cause explanation. This program can often bring you into full compliance without triggering offshore penalties. File 3 amended returns for each of the past 3 years (assuming you have not filed the informational return for all three years), Forms 5471 (assuming that is the missing form) for each year, a reasonable cause statement, and, potentially, Forms 8938 (FATCA) if the balance on the company accounts (previously unreported) puts you over the threshold.
You are current on tax returns but have not filed FBARs and/or Forms 8938 (FATCA):
Missing FBARs only, but all income (e.g., interest from foreign bank accounts) was reported on your federal tax return → You may use the Delinquent FBAR submission procedures to file FBARs without amending tax returns. This program allows you to come into compliance without penalties. Cost: $510 for six years of FBAR filings if you do it through your TFX account.
Missing FBARs and unreported income (e.g., interest from foreign bank accounts) on your federal tax return → Streamlined procedures are usually the best option because they correct both problems. Filing late FBARs without amending tax returns would leave part of the issue unresolved. File 3 amended tax returns and 6 FBAR reports, and the Streamlined certification letter (Form 14653 or 14654) through the Streamlined procedures. Cost: $1,450/$1,650 for the Streamlined procedures package + $420 for three amended tax returns (these prices include a multi-year discount from our normal pricing), and $300 for the Streamlined certification letter (Form 14653). In this case, your assigned tax preparer will handle your FBARs.
Missing FBARs and Forms 8938 (FATCA), but all income (e.g., interest from foreign bank accounts) was reported on your federal tax return → You must still file 3 amended returns (because Form 8938 is a part of Form 1040), 3 Forms 8938 (FATCA), 6 FBAR reports, and the Streamlined certification letter (Form 14653 or 14654) through the Streamlined procedures. Cost: $1450/$1650 for the Streamlined procedures package + $240 for Form 8938 filings (up to 5 accounts) + $420 for amended returns (these prices include a multi-year discount from our normal pricing), and $300 for the Streamlined certification letter (Form 14653).
You filed FBARs but never filed tax returns → You may still use Streamlined procedures. You will file 3 years of tax returns, 6 years of FBARs (which you have already filed), and the Streamlined certification letter (Form 14653 or 14654). Cost: $1450/$1650 for the Streamlined procedures package + $300 for the Streamlined certification letter (Form 14653).
⚠️ Note: Already filed FBARs, as long as they are correct and contain all of your non-U.S. financial accounts (checking, savings, brokerage, pension, etc.), do not need to be refiled. However, you will need to include the printout of your FBAR filing confirmations from the Treasury. Refer to How to verify if FBAR was filed (similar to a tax transcript).
Choosing the wrong path can be costly. Always review your situation with a qualified tax professional. Schedule a free intro consultation with one of our tax experts before filing anything.
5. Why use Streamlined procedures instead of just filing late returns?
5. Why use Streamlined procedures instead of just filing late returns?
Because filing late returns alone does not protect you from:
Failure-to-file penalties
Failure-to-pay penalties
Accuracy-related penalties
FBAR penalties (which can be extremely severe)
Streamlined procedures are specifically designed to eliminate or reduce these penalties when non-compliance was non-willful. For more information, refer to What happens if you don’t file taxes while living abroad? Penalties & IRS rules explained.
6. What if I did not have to file FBARs (the highest balances of all foreign assets were below $10,000)? Would I be saved from FBAR penalties?
6. What if I did not have to file FBARs (the highest balances of all foreign assets were below $10,000)? Would I be saved from FBAR penalties?
Yes. You would also not be subject to the failure-to-file and failure-to-pay penalties and accuracy-related penalties if you filed your tax returns on time.
7. Should I contact the IRS beforehand and let them know I will be sending in my forms soon?
7. Should I contact the IRS beforehand and let them know I will be sending in my forms soon?
No, do not contact the IRS preemptively. The best first contact with the IRS is a properly prepared filing. In the very odd case that they get in contact with you, let them know that you are working on compliance with us. Our usual turnaround is generally faster than any deadline they'll impose on you, anyway.
8. Should I file an extension of time to file before submitting the Streamlined package?
8. Should I file an extension of time to file before submitting the Streamlined package?
No. Do not file an extension before submitting your Streamlined package if you are delinquent for multiple years. Filing an extension may affect eligibility. Always consult your tax preparer first.
Questions you might have on the logistics of filing Streamlined procedures with TFX
1. How does the Streamlined procedures preparation process work?
1. How does the Streamlined procedures preparation process work?
We prepare your filings step by step to ensure accuracy and avoid carrying errors from one year to the next:
You fill in and submit six Tax Questionnaires (TQs) for our review.
We review your TQs and request additional questions if needed.
We prepare an Engagement letter (EL).
You sign the EL and prepay $200 or the full amount listed in the EL.
We prepare the earliest required year (i.e., current tax year minus 3 years).
You pay for that tax return, or the bill amount is automatically deducted from the available credits on your TFX account.
You review and approve the return (or request changes if anything concerns you, and we will revise it).
We then proceed to the next year. This step-by-step approach prevents errors from rolling forward.
After all three tax returns are finalized, we prepare the six years of FBARs.
You review and approve the FBARs.
We e-file the FBARs with the U.S. Treasury and upload the e-filing confirmation (acknowledgment) to the Documents section of your TFX account.
We provide detailed instructions on how to assemble and mail your Streamlined package to the IRS.
You download and print the files, wet-sign the papers, and mail the SP package to the IRS.
Note: Payment is due once a return is prepared. The document will appear in the Documents section of your TFX account but will remain locked until payment is received. Once payment is posted, the return unlocks automatically for your review.
2. Can I speak with someone before I start the Streamlined procedures preparation?
2. Can I speak with someone before I start the Streamlined procedures preparation?
Our standard service fees do not include phone consultations. However, you do have two options if you would like to speak with a tax professional:
Before signing the Engagement Letter: You can schedule a free introductory phone consultation with one of our tax advisors. This may require a $50 retainer, which will be applied toward your future tax preparation fees.
After signing the Engagement Letter: You can schedule a 30-minute phone consultation with your assigned tax preparer directly from your TFX account for $150, if email communication is not sufficient.
3. How long does the process take?
3. How long does the process take?
The preparation of one year takes up to ~15 business days. Multi-year cases typically take 1–2 months, depending on complexity and how quickly you provide the required information to us.
4. Can spouses file Streamlined together?
4. Can spouses file Streamlined together?
A: Yes, if filing jointly. Our price for the joint SP filing is the same as for an individual SP filing. However, additional FBAR fees may apply if both spouses have separate foreign financial accounts.
5. Which years must be filed?
5. Which years must be filed?
The IRS requires you to file only tax years that are already delinquent (past due) at the time you submit your streamlined package, regardless of how many years you have actually missed.
Under the Streamlined procedures, you must file:
3 most recent delinquent tax years (federal income tax returns), and
6 most recent delinquent FBAR years
Example (as of late 2025):
Tax returns: 2022–2024
FBARs: 2019–2024
You should not include the current year if it is not yet late. The 2025 tax return is not delinquent yet, so it must not be included in the streamlined package. The 2025 tax return will be overdue (for those abroad) on June 15, 2026. After mailing your streamlined submission, you should wait about 45 days before filing your next regular (non-streamlined) tax return.
6. How do I complete the Tax Questionnaire (TQ) for Streamlined procedures?
6. How do I complete the Tax Questionnaire (TQ) for Streamlined procedures?
A: When you log in to your TFX account and create a Tax Questionnaire, we will ask if you are filing for one or more years. If you indicate you are delinquent on multiple years, the system will offer the Streamlined procedures option and automatically generate six questionnaires. Refer to How to create 3 standard TQs and 3 FBAR Only TQs for Streamlined procedures.
7. What kinds of accounts should be reported in the Non-U.S. Financial Accounts tab?
7. What kinds of accounts should be reported in the Non-U.S. Financial Accounts tab?
Any financial account located outside the U.S. must be reported if the filing threshold is met. Please see:
8. Do I need to complete foreign account info even if I don't have $10,000 across my accounts?
8. Do I need to complete foreign account info even if I don't have $10,000 across my accounts?
Unfortunately, yes. Joining the Streamlined procedures program requires filing FBARs for the last six years, regardless of whether you were required to do so due to the balances on your foreign accounts in specific years.
Remember to avoid using our automated FBAR filing service in the Compliance monitor section of your TFX account — your assigned tax preparer will manually e-file six FBARs for you as part of the Streamlined procedures package.
9. Do I need to provide bank statements?
9. Do I need to provide bank statements?
No. We rely on your self-reported account information.
10. Do I need to report the end-of-year account value for each account, or the highest account value within the year?
10. Do I need to report the end-of-year account value for each account, or the highest account value within the year?
FBAR requires reporting the highest balance during the year, not the year-end balance.
11. Can I provide estimated balances?
11. Can I provide estimated balances?
Yes. If you don’t have exact figures, you can provide your best effort estimate.
12. I input the maximum account value for all accounts in the Non-U.S. Financial Accounts tab, but there is a "Maximum account value unknown" checkbox underneath that says “Check to confirm”. If I don’t tick it, I get an error when submitting my answers.
12. I input the maximum account value for all accounts in the Non-U.S. Financial Accounts tab, but there is a "Maximum account value unknown" checkbox underneath that says “Check to confirm”. If I don’t tick it, I get an error when submitting my answers.
Don't worry. The "Maximum account value unknown" question can be left unchecked as long as you provided the highest balance during the year. You can submit your answers even if you see this “Check to confirm” checkbox highlighted. The "Maximum account value unknown" question is optional. You can tick this box if you do not know the highest balance during the year, and cannot provide an estimated balance (for example, pension accounts).
13. How do I report the interest earned on the accounts I provide details for in the Non-U.S. Financial Accounts tab?
13. How do I report the interest earned on the accounts I provide details for in the Non-U.S. Financial Accounts tab?
You should report all interest earned in the Passive Income > Interest tab of the TQ. Refer to Reporting investment income: dividends, interest, capital gains, etc.
14. What is a certification letter?
14. What is a certification letter?
A Streamlined certification letter is the IRS Form 14653 (SFOP) or Form 14654 (SDOP), where you certify your non-willfulness. You could either complete it yourself, or we could do it for you. In general, we recommend having this done professionally.
The IRS instructions on a certification letter:
Complete and sign a statement on the certification by U.S. person residing outside of the U.S. certifying:
that you are eligible for the Streamlined Foreign Offshore Procedures;
that all required FBARs have now been filed; and
that the failure to file tax returns, report all income, pay all tax, and submit all required information returns, including FBARs, resulted from non-willful conduct.
Submit the original signed statement and attach copies of the statement to each tax return and information return being submitted through these procedures. You should not attach copies of the statement to FBARs. Failure to submit this statement, or submission of an incomplete or otherwise deficient statement, will result in returns being processed in the normal course without the benefit of the favorable terms of these procedures.
15. Can TFX e-file Streamlined returns?
15. Can TFX e-file Streamlined returns?
Unfortunately, tax returns filed under the Streamlined procedures must be mailed. We will e-file the FBARs for you and provide PDF files of all your returns along with detailed instructions on how to prepare the package and send it to the IRS.
16. How will I know if the IRS accepted my Streamlined submission?
16. How will I know if the IRS accepted my Streamlined submission?
The IRS no longer sends formal acceptance letters. In most cases, no news is good news. If the IRS needs additional information, they typically contact you within two months after your filing.