IRS tax amnesty for expats: every way to catch up, compared
The IRS doesn't run a program called an amnesty. For Americans abroad who fell behind by mistake, the closest thing is the Streamlined Foreign Offshore Procedures: you file three years of returns and six years of FBARs, pay any tax due plus interest, and owe no penalties if you qualify. Other situations have other routes, all compared below.
Living outside the U.S.? Find your country's guide.
Every IRS catch-up option, compared
Find the row that sounds like you. Most of our clients are in the first one.
| Option | Who it's for | Penalty | Years filed | Risk |
|---|---|---|---|---|
| Streamlined Foreign Offshore | You live abroad and didn't know the rules | None | 3 returns + 6 FBARs | Low, if you qualify |
| Streamlined Domestic Offshore | You live in the U.S., filed, but missed foreign accounts | 5% of foreign assets | 3 amended returns + 6 FBARs | Low, if you qualify |
| Delinquent FBAR procedures | Your income was all reported, only FBARs are missing | Usually none | Late FBARs + a statement, usually 6 years | Low |
| Late international forms | Your income was all reported, forms like 5471, 3520 or 8938 are missing | Possible | The late forms + a reasonable cause statement | Medium: penalties aren't ruled out |
| Relief for former citizens | You already renounced and never filed | None, tax forgiven | 6 years of returns + Form 8854 | Low, if you qualify |
| Voluntary disclosure | You knew and chose not to report | Significant | Usually 6 years | Protects against prosecution, if accepted |
| Quiet disclosure | Filing past years, or just this year, outside any program | Not waived | Whatever you choose | High: old years and penalties stay open |
1Which IRS tax amnesty option fits you?
Answer these in order. The first one that matches is usually your route.
- Did you know you had to file or report, and decide not to? Then the Streamlined procedures aren't open to you, and voluntary disclosure is the route.
- Have you already given up U.S. citizenship, and never filed? Check relief for former citizens first. If you qualify, the past tax is forgiven.
- Did you file every U.S. return, with all your foreign income on it? Then only forms are missing: late FBARs go through the Delinquent FBAR procedures, and forms like 5471, 3520 or 8938 through the late international forms route.
- In any of the last three years, did you spend 330 full days outside the U.S. without a U.S. home? Then it's the Streamlined Foreign Offshore Procedures, with no penalty.
- Did you live in the U.S. all three years, and file returns that left out foreign income? Then it's the Streamlined Domestic Offshore Procedures, with a 5% penalty.
- None of these? Some situations need a mix, or a route outside the procedures. That's what the consultation is for.
The full eligibility check runs through the same questions and shows your likely route.
2Is there really an IRS tax amnesty for expats?
Not by that name. "Amnesty" is what people search for, and what ads promise. The IRS's own term is the Streamlined Filing Compliance Procedures, in place since 2012 and expanded in 2014.
For Americans abroad, they do most of what the word suggests:
- The penalties go. Missing FBARs and forms like 8938 or 5471 can carry penalties of $10,000 or more per form, per year, even when no tax is owed. Under the foreign version, they're waived if you qualify.
- The past is drawn under a line. You file a set number of years, three returns and six FBARs, not every year you missed.
- The tax isn't forgiven. You pay any tax actually due, with interest. For many expats that's little or nothing, because of the foreign earned income exclusion and the foreign tax credit.
- It's not a free pass. You sign a statement under penalty of perjury that your conduct was non-willful, and you file on time from then on.
The procedures have no end date, but the IRS can close them at any time. They also stop being available to you once the IRS opens an examination. What exists, and what doesn't, in 2026.
3What does each option involve?
Streamlined Foreign Offshore Procedures
For U.S. citizens and green card holders abroad who didn't file, or left foreign income off their returns, by mistake. You file three returns, six FBARs and Form 14653, and pay any tax and interest. No penalties if you qualify. The full guide.
Streamlined Domestic Offshore Procedures
For U.S. residents who filed their returns but left out foreign income or accounts. You amend three returns, file six FBARs and Form 14654, and pay a 5% penalty on the highest year-end total of the foreign assets involved. Work out your 5%.
Delinquent FBAR Submission Procedures
For people whose returns are filed with all their income, who only missed FBARs. You file the late FBARs online with a short statement, and there's usually no penalty. How it works. Filed the FBARs, but with a mistake? That's an amended FBAR, not a late one.
Late international information returns
For people whose income was all reported but who missed forms like 5471, 3520 or 8938. The forms go in with a reasonable cause statement. Penalties aren't ruled out, which is why the statement matters. How it works.
Relief for former citizens
For people who renounced after March 18, 2010, with a net worth under $2 million and $25,000 or less of U.S. tax for the six years. You file the returns and Form 8854, and the tax is forgiven. Who qualifies.
Voluntary disclosure
For people whose conduct was willful. It's run by IRS Criminal Investigation, and it trades significant penalties for protection from prosecution, if you're accepted. How it works.
Quiet disclosure
Not a program: filing past years, or just this year, without using one. It waives nothing, and the years you skipped stay open. Why it's riskier than it looks, and how it compares with Streamlined.
4Three people, three routes
| Person | Situation | Route | Penalty | Our flat fee |
|---|---|---|---|---|
| Sam, in Toronto since 2012 | Never filed U.S. returns or FBARs; Canadian salary, a TFSA and an RRSP | Streamlined Foreign Offshore | $0 | $1,399 |
| Jordan, back in Austin since 2018 | Files every year, but never reported a UK savings account and ISA | Streamlined Domestic Offshore | 5% of the highest year-end total | $1,999 |
| Robin, in London since 2016 | Files every year with all income reported, but never filed an FBAR | Delinquent FBAR procedures | Usually $0 | $499 |
Sam owes little or no U.S. tax: Canadian tax on the salary is usually higher than the U.S. tax, and the foreign tax credit offsets it. Jordan's tax on the UK interest and ISA income is due with interest, plus the 5%. Robin's returns don't change at all.
5What does the IRS tax amnesty for expats cost?
The IRS charges nothing to use the procedures. You pay any tax actually due with interest, and the 5% penalty if you use the domestic version, all straight to the IRS. Our fees are flat and agreed upfront in writing:
- Streamlined, with FBARs: $1,399 for three returns, six FBARs and Form 14653.
- Streamlined, without FBARs: $1,099, if your accounts never added up to more than $10,000.
- Streamlined Domestic: $1,999, with the 5% base worked out with you.
- Late FBARs only: $499 for six years, statement included.
Extras like foreign funds or a foreign company are priced per year, only if you need them. See all prices. The consultation is free, with no obligation, and we'll tell you honestly where you stand before you pay us anything.
6How do we get you caught up?
- A free consultation. We figure out which option fits, based on where you've lived, what you missed and why. You answer a few questions online.
- We prepare everything. Every return, FBAR and form, plus your non-willful statement, written with you. You upload documents and review.
- We e-file, you mail. We e-file your FBARs and give you the finished package, then stay with you until it's processed. You print, sign and mail it.
The IRS decides who qualifies for each procedure. We don't guarantee a specific outcome, and we'll say so plainly if a route doesn't fit.
7What mistakes do people make choosing a route?
- Picking the FBAR-only route when income wasn't reported. Interest on a savings account, or growth in an ISA or TFSA, often never made it onto the U.S. return. Then the Delinquent FBAR procedures don't fit, and Streamlined does.
- Assuming the domestic version after moving back. One year abroad among the last three, with 330 full days outside the U.S., can open the foreign version and save the 5%.
- Filing quietly first. Filing this year, or a few old years, on their own doesn't waive anything, and it complicates the story you tell later.
- Writing a boilerplate statement. The non-willful statement has to describe your own facts. One copied from a template is weaker, and it's signed under penalty of perjury.
- Certifying non-willful conduct when it wasn't. If you knew and chose not to report, Streamlined is the wrong route, and voluntary disclosure exists for that.
- Waiting for a better amnesty. For non-willful expats, the foreign version already waives the penalties. An IRS letter, or the procedures closing, can end that option.
Guides by country
Local accounts, pensions and tax treaties change how these rules play out. Each guide below covers them for one country, with its tax year and filing dates.
- Argentina
- Australia
- Austria
- Belgium
- Brazil
- Canada
- Chile
- China
- Colombia
- Costa Rica
- Croatia
- Cyprus
- Denmark
- Dominican Republic
- Ecuador
- France
- Germany
- Greece
- Hong Kong
- India
- Ireland
- Israel
- Italy
- Japan
- Malaysia
- Malta
- Mexico
- Netherlands
- New Zealand
- Norway
- Panama
- Philippines
- Poland
- Portugal
- Saudi Arabia
- Singapore
- South Africa
- South Korea
- Spain
- Sweden
- Switzerland
- Taiwan
- Thailand
- UAE
- United Kingdom
- Vietnam
Live somewhere else? We help there too.
Common questions
Is the IRS amnesty program for expats official?
The procedures are official IRS programs. "Amnesty" is just the popular name. The formal names are the Streamlined Foreign Offshore Procedures and the Streamlined Domestic Offshore Procedures, together the Streamlined Filing Compliance Procedures.
Is the expat tax amnesty ending?
There's no announced end date. The IRS has said it can close the procedures at any time, so there's no advantage in waiting, and they close for you personally once the IRS opens an examination.
Do I have to file every year I missed?
No. Under the Streamlined procedures you file the last three years of returns and six years of FBARs, however long you've been away.
Does the amnesty work for Canadian, UK and Australian residents?
Yes. The Streamlined procedures apply to U.S. citizens and green card holders anywhere. Each country has its own wrinkles, like TFSAs in Canada, ISAs in the UK and superannuation in Australia. See country guides.
Can green card holders use it?
Yes, if they meet the conditions. Green card holders file like citizens for as long as they hold the card. Green card holders abroad.
Can I just start filing this year and skip the past?
That's called a quiet disclosure. It doesn't waive any penalties, and the years you skipped stay open. Why it's riskier than it looks.
Does Streamlined cover foreign mutual funds and ETFs?
Yes. Funds based outside the U.S. are usually PFICs, with their own tax rules and, in most cases, a Form 8621 for each fund in each year you file. How PFICs are taxed.
What if I've never had a Social Security number?
You'll need a taxpayer ID. Many accidental Americans apply for an SSN first; if you're not eligible, an ITIN application can go in with your returns.
What happens after I file?
There's no acceptance letter. The IRS processes the returns like any others and writes only if something needs attention, which can take months. From then on, you file every year as normal.
Ready to find your option? Start here.
Tell us your situation. Our tax team will tell you which procedure fits, and what it would cost.
Get in touch →