What are the IRS Streamlined Filing Compliance Procedures?

They're an IRS program that lets US taxpayers who failed to report foreign income or file required foreign account forms — because of non-willful conduct — get compliant by filing three years of amended or delinquent returns and six years of FBARs. Taxpayers living abroad who qualify under the Streamlined Foreign Offshore Procedures pay no failure-to-file, failure-to-pay, or FBAR penalties.

What does non-willful mean for the streamlined program?

Non-willful conduct is conduct due to negligence, inadvertence, mistake, or a good-faith misunderstanding of the law — not a deliberate choice to hide income or evade tax. You certify your non-willfulness under penalty of perjury on Form 14653 (for taxpayers abroad), and that certification is the heart of the submission.

How many years of returns and FBARs does the streamlined program require?

Three years of the most recent delinquent or amended income tax returns, and six years of delinquent FBARs (FinCEN Form 114). You pay any tax due on those three years plus interest, but qualifying expats abroad avoid the penalties that would otherwise apply.

Can I use the streamlined procedures if the IRS has already contacted me?

Generally no. The Streamlined Procedures are only available if the IRS has not already initiated a civil examination or criminal investigation of your returns for any year. If you're already under audit, or your conduct was willful, you need a different path — such as the Voluntary Disclosure Practice — and should get professional advice before filing anything.

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Expats / Expatriate Tax

Streamlined Filing Compliance Procedures: How Expats Catch Up Without Crushing Penalties

Behind on US tax returns or FBARs while living abroad? The IRS Streamlined Procedures let non-willful filers get current with three years of returns, six years of FBARs, and dramatically reduced penalties.

SMAART Tax Team

March 9, 2026

6 min read