Streamlined Filing Compliance Procedures

The Streamlined Filing Compliance Procedures are the IRS program for non-willful taxpayers to catch up on unreported foreign income and accounts by filing three years of returns and six years of FBARs with a certification of non-willfulness; the domestic version carries a 5 percent penalty and the foreign version none.

Eligibility turns on residency (which version applies) and on willfulness (whether the program applies at all). Taxpayers under examination are not eligible.

Why it matters: choosing between the domestic and foreign procedures, and between streamlined and voluntary disclosure, is the decision that matters most. See Streamlined Domestic. See Streamlined Foreign.

Where this comes up in our work

International tax attorneys

FBAR, FATCA, streamlined procedures, voluntary disclosure, and foreign trust and gift reporting.

See the practice page →

Have a question about this?

Our tax attorneys handle IRS audits, crypto tax, offshore disclosures, and opinion letters for clients nationwide. Consultations are confidential.

Definitions are general information, not legal advice, and may not reflect the most recent changes in law.