Catching up
Behind on US filings? There is an orderly way back.
Many Americans in the UK only learn about their US filing obligations years after moving. The IRS Streamlined Foreign Offshore Procedures exist for exactly this situation: where the failure to file was non-wilful, you file the most recent 3 years of returns and 6 years of FBARs with a signed certification, and the usual failure-to-file, failure-to-pay, accuracy-related and FBAR penalties do not apply if the submission is accepted. Tax and interest remain due.
Who this is for
- US citizens and green card holders abroad who have never filed, or stopped filing
- People who filed returns but missed FBARs, Form 8938 or PFIC reporting
- Accidental Americans who have received a FATCA letter from a UK bank
- Anyone who has been told they need to catch up and wants the position assessed properly first
What we prepare
- Eligibility assessment
- Whether you meet the non-residency test (no US abode and at least 330 full days outside the US in at least one of the three years) and whether the conduct was non-wilful.
- Three years of returns
- Delinquent or amended Forms 1040 with every information return that should have accompanied them (Forms 8938, 8621, 5471, 3520 as relevant).
- Six years of FBARs
- FinCEN Form 114 for each year, filed electronically with the required Streamlined explanation.
- Form 14653 certification
- A factual, carefully written statement of why the failure was non-wilful. This is the document the IRS reads most closely, and we draft it with you from the facts, not from a template.
- Tax and interest computation
- The payment that must accompany the submission, with the exchange rates and workings documented.
Honest expectations
Streamlined is not a negotiation and we do not promise a particular outcome. What we commit to is a complete, accurate and properly disclosed submission that follows the IRS instructions exactly. Where your facts do not fit the procedures, for example where conduct could be seen as wilful, or you did not meet the non-residency test, we tell you before any work starts and set out the alternatives.
The submission is filed on paper to the IRS Austin unit. Processing times vary and the IRS does not send an acceptance letter; the absence of penalty notices and the processing of the returns is how acceptance is normally evidenced.
Why the order matters
If you also have UK filings outstanding, we deal with both. Fixing the US side while leaving UK Self Assessment open, or the reverse, creates new problems later. Where UK tax was paid in the years concerned, it also drives the Foreign Tax Credit that often reduces the US tax to nil.
Process
How it works
- 01
Tell us the history
Years abroad, what has ever been filed, and all income sources in every country for the last three years. We treat this as confidential.
- 02
Assessment and written quote
We confirm whether Streamlined fits, what years and forms are needed, and the fee, before any work.
- 03
Onboarding and document list
Identity checks, engagement letter, then a year-by-year checklist in the portal.
- 04
Preparation
Returns, FBARs, the certification and the tax computation, reviewed by a second person.
- 05
Your review and signature
You review everything in the portal, sign the certification and returns, and we assemble the paper submission and file the FBARs electronically.
FAQ
Questions we are asked
How many years do I have to file?
The most recent 3 years of tax returns for which the due date has passed, and the most recent 6 years of FBARs. Earlier years are not required under the procedures.
Will there be penalties?
If you are eligible for the Foreign Offshore route and the submission is complete and accurate, the IRS states that failure-to-file, failure-to-pay, accuracy-related, information-return and FBAR penalties will not be applied. Tax and statutory interest are still due. Nothing we do can change that, and we will not suggest otherwise.
What does non-wilful mean?
The IRS defines it as conduct due to negligence, inadvertence or mistake, or a good-faith misunderstanding of the law. Not knowing you had to file because you have lived in the UK since childhood is a common and credible example. Deliberately hiding accounts is not.
I owe nothing after credits. Do I still need Streamlined?
Often yes. Streamlined also covers missed information returns and FBARs, which carry penalties even where no tax is due. If you only missed FBARs and reported all income, the separate Delinquent FBAR procedure may fit better; we assess that first.
How much does it cost?
The fee depends on the number of years, the income types and the information returns involved. We quote in writing once we have the full picture. We do not quote before that, because an inaccurate quote helps nobody.
Written by the US UK Expat Tax advisory team. Last reviewed 7 November 2026
Primary sources checked
General information, not personal tax advice. Rules and thresholds change; we confirm the position for your facts before any work.
Get started
Tell us your situation
Where you live, which years are involved, what has been filed, and every source of income in each country. We reply by email within two working days with what is needed and a written fee. No free consultations, and no work starts before you have the quote.