Streamlined compliance procedures for U.S. taxpayers

At Expand CPA, we assist individual taxpayers, U.S. citizens, green card holders, and foreign residents who have failed to file required tax returns or properly report offshore income, foreign bank accounts, and financial assets. Our international tax advisors guide you through the IRS Streamlined Filing Compliance Procedures—whether you’re eligible under the Streamlined Foreign Offshore Procedure (SFOP) or the Domestic Streamlined Program.

This IRS-approved program is designed for taxpayers whose failure to comply was non-willful, due to mistake, negligence, or misunderstanding of the law. It allows eligible individuals to submit delinquent tax returns, FBARs (FinCEN Form 114), and required certifications to become fully compliant without facing substantial penalties or criminal investigation.

With a presence in the United States, France, and Israel, our firm provides professional guidance tailored to each client’s circumstances. Whether you’re an expat residing abroad or a permanent resident in the U.S., we ensure timely and accurate submission of all required forms—including Form 14653—and support you in every step of the streamlined compliance process.

By working with Expand CPA, you benefit from a structured, lawful, and favorable solution to resolve past filing failures, avoid unnecessary penalties, and meet all IRS reporting requirements. Contact us to determine your eligibility and receive assistance from certified experts in international tax law and voluntary disclosure procedures.

SERVICES

Our key services

Eligibility assessment for the Streamlined Procedure: We analyze whether you meet the eligibility criteria as a U.S. taxpayer—resident or non-resident—based on your specific filing history and conduct.

Preparation of delinquent U.S. tax returns: We assist with filing up to three years of overdue federal tax returns to help you become fully compliant.

Foreign Bank Account Reporting (FBAR) assistance: We prepare and file up to six years of FinCEN Form 114 to report offshore accounts and foreign financial assets, as required by law.

Penalty mitigation and tax optimization: As international tax advisors, we structure your submission to minimize or eliminate penalties under the applicable streamlined compliance program.

Preparation and submission of IRS forms: We handle all required forms, including Form 14653 for non-residents, with accuracy and in accordance with IRS instructions.

ITIN application support: If you do not yet have an Individual Taxpayer Identification Number (ITIN), we assist with your application through an IRS-authorized Certifying Acceptance Agent.

IRS representation and communication: We represent you before the IRS, including in cases of audit, request for additional documentation, or submission clarification.

Post-compliance tax planning: Once your situation is regularized, we provide strategic advice to ensure ongoing U.S. tax compliance and optimized international reporting.

What is the streamlined filing compliance procedure?

The streamlined compliance procedures were introduced by the IRS to help taxpayers—both U.S. residents and individuals living abroad—become compliant with their U.S. tax obligations when they failed to file returns or report foreign financial accounts due to non-willful conduct.

These IRS streamlined procedures are specifically designed for eligible taxpayers who did not properly report income, pay tax, or submit required information returns (including FBARs and Form 8938) because of a misunderstanding, negligence, or a lack of awareness of the requirements.

Depending on your residency status, you may qualify for:

Streamlined Foreign Offshore Procedures (SFOP) if you live outside the United States,
Streamlined Domestic Offshore Procedures if you reside in the U.S. but failed to meet your reporting obligations.

Participation in the streamlined compliance procedures requires filing delinquent tax returns for the last three years, FBARs for the past six years, and submitting a detailed certification statement (such as Form 14653) to confirm that your non-compliance was not willful.

This process allows eligible individuals to avoid substantial penalties, including failure-to-file and accuracy-related penalties, and brings them into full compliance with U.S. tax law—without the risk of criminal investigation.

Who qualifies for the streamlined procedure?

To qualify for the streamlined compliance procedures, a taxpayer must meet several conditions related to conduct, residency, and prior tax compliance. The program is open to both U.S. citizens and green card holders—whether residing in the United States or abroad—who have not met their U.S. tax filing obligations but did so without willful intent.

To be eligible:

The taxpayer must demonstrate non-willful conduct, meaning the failure to file tax returns, report foreign income, or disclose offshore financial accounts resulted from a mistake, negligence, or misunderstanding of the legal requirements—not from an intent to evade tax.
The residency status of the individual determines whether the Streamlined Foreign Offshore Procedures (SFOP) or the Streamlined Domestic Offshore Procedures apply. This affects the penalty framework and required documentation.
The taxpayer must have failed to submit one or more required forms, such as Form 1040, FBAR (FinCEN Form 114), or Form 8938, in prior years.
A certification statement (Form 14653 for non-residents) is required, in which the taxpayer must declare that the non-compliance was non-willful and provide a narrative explaining the circumstances.

Your trusted partner for U.S. tax compliance

With offices in New York, Paris, and Tel Aviv, Expand CPA is ideally positioned to assist individuals with international tax obligations. Our U.S.-based team has in-depth experience with the IRS, including the streamlined compliance procedures and ITIN applications.

We offer clear, reliable guidance to help reduce risks, avoid penalties, and bring your tax situation into full compliance—whether you’re residing in the United States or abroad.

Frequently asked questions

How can I catch up on taxes I haven’t filed?

To catch up on taxes, the IRS offers streamlined filing procedures for eligible individuals who failed to comply due to non-willful conduct. Under this program, you can file past-due returns for the last three years and up to six years of FBARs, avoiding many of the penalties typically associated with late filings.

What is the IRS Streamlined Program?

The IRS streamlined program—also known as the IRS Streamlined Foreign Offshore Procedures—is a voluntary disclosure process for U.S. taxpayers who failed to report foreign income, assets, or accounts but did so unintentionally. It allows qualifying individuals to get back into compliance without facing severe civil or criminal penalties.

What are the penalties for late filing?

Normally, there are significant penalties for late filing, including failure-to-file and failure-to-pay penalties, and sometimes accuracy-related penalties. However, under the streamlined procedures, no penalties are imposed if you qualify and your failure to comply was non-willful. This makes it a favorable option for taxpayers seeking a clean slate.

How do I report foreign income and accounts?

If you have foreign accounts or income from overseas assets, you're required to report them annually to the IRS using forms such as FBAR (FinCEN Form 114) and, in some cases, Form 8938. The streamlined compliance procedures help you report these correctly and retroactively if you missed past filings, while minimizing legal and financial risks.

What is the process for streamlined filing?

The process for streamlined filing involves several steps. First, we assess your eligibility based on your residency and filing history. Then, we help you prepare and submit up to three years of delinquent tax returns and six years of FBARs. As part of the streamlined submission, you’ll also need to complete a certification form (such as Form 14653) to confirm that your previous non-compliance was not willful. Once submitted, the IRS reviews your case without initiating a full examination in most situations.

Would you like to optimise your tax situation?

Expand CPA supports you in France and the United States to effectively manage your accounting and tax obligations. Take advantage of personalised advice to secure your activities and develop your business internationally. Contact us to schedule a meeting or ask questions about our services.