Key Takeaways The Streamlined Procedures offer two tracks: Streamlined Domestic Offshore (for US residents) and Streamlined Foreign Offshore (for qualifying taxpayers abroad) Eligibility requires certifying under penalty of perjury that non-compliance was non-willful The domestic program applies a 5% miscellaneous offshore penalty on the highest aggregate balance of unreported foreign assets The foreign program applies no penalty beyond taxes and interest owed You must file 3 years of amended/delinquent tax returns and 6 years of delinquent FBARs Contact Neil Jesani Tax Resolution to determine your eligibility and prepare your submission What Are the IRS Streamlined Filing Compliance Procedures? The IRS Streamlined Filing Compliance Procedures were introduced in 2012 and significantly expanded in 2014 to provide a simplified path for taxpayers to come into compliance with their international tax reporting obligations. These procedures are specifically designed for taxpayers whose failure to report foreign financial assets, pay tax on foreign income, and file international information returns was due to non-willful conduct — meaning the failure resulted from negligence, inadvertence, or a good-faith misunderstanding of the requirements. The Streamlined Procedures offer substantial advantages over other compliance options, including significantly reduced penalties, no IRS enforcement action risk, and a streamlined review process. For eligible taxpayers, these procedures represent the most cost-effective and least risky path to resolving international tax compliance issues. Two Tracks: Domestic vs. Foreign Offshore The Streamlined Procedures are divided into two separate programs based on where the taxpayer resides: Streamlined Domestic Offshore Procedures (SDOP) The Streamlined Domestic Offshore Procedures are available to US taxpayers who reside in the United States . This program applies to US citizens and residents who have been living in the US and have failed to report foreign financial accounts and/or pay tax on foreign income. Key features include: Penalty structure: A 5% miscellaneous offshore penalty is...