Who this is for
- US citizens, green card holders and other US taxpayers living abroad who have decided to use the Streamlined Foreign Offshore Procedures
- Filers assembling, mailing or correcting a streamlined package, including married couples and estates
Not covered here
- Whether you qualify and which years are covered
- Which accounts belong on each FBAR, and how to fill out each information return
- Filing status with a nonresident spouse, and state returns
SFOP package checklist: what goes in the envelope?
A Streamlined Foreign Offshore package covers the most recent three tax years whose filing due date (or properly extended due date) has passed, plus six years of FBARs. Everything except the FBARs goes in one paper package to the IRS in Austin. The IRS instructions list each item:
| Item | What to include | How it is sent |
|---|---|---|
| Tax returns | One for each of the three years: Form 1040 if never filed, Form 1040-X if filed before | Paper, in the package |
| Information returns | Every one required for those years, such as Forms 3520, 5471 and 8938, even ones normally filed separately | Paper, with each year's return |
| Red marking | "Streamlined Foreign Offshore" written in red at the top of the first page of each return and the top of each information return | On the paper forms |
| Form 14653 | The original signed form, plus a copy attached to each return and each information return | Paper, in the package |
| Payment | All tax shown on the returns plus interest, with your taxpayer identification number (Social Security number or ITIN) on the check | Paper, in the package |
| ITIN application | Only if you are not eligible for a Social Security number and have no ITIN | Paper, in the package |
| Treaty deferral election | Only to claim late treaty deferral on a foreign retirement or savings plan: the deferral election itself, made with the returns, plus two statements | Paper, in the package |
| Six FBARs | Any missing or incorrect FBAR for the six most recent years whose FBAR due date has passed | E-filed with FinCEN, not in the envelope |
The IRS says that missing any item, or sending an incomplete or deficient Form 14653, means the returns are processed in the normal course without the streamlined terms. The penalty relief depends on the package being complete.
The order of work:
- E-file the late FBARs.
- Prepare and sign the returns and Form 14653.
- Mail one package with the check.
Every return also needs a valid taxpayer identification number. A US citizen or green card holder who is eligible for a Social Security number but does not have one cannot use the procedures yet: the IRS processes a submission without a valid number with the normal penalties (FAQ 10).
A package is not simple when you file with a spouse, own a foreign pension, foreign funds or a foreign company, or had an adviser who told you something different. Before you start, gather six years of statements for every foreign account, three years of income records and foreign tax returns, any US returns you did file, and the facts for your narrative: where each account's money came from and why you did not file. Whether you qualify, and which years count, is covered in who can use the Streamlined Foreign Offshore Procedures.
Do I file original Forms 1040 or Forms 1040-X for each year?
Decide year by year: send an original Form 1040 for a year you never filed, and a Form 1040-X for a year you already filed. A package can hold both. Each return must be complete and accurate, with all the information returns that year requires attached (IRS instructions).
Information returns that you would normally send to a different IRS address, such as Form 3520, go inside the package with the return for the same year. Each one carries the red "Streamlined Foreign Offshore" heading and a copy of Form 14653.
If you plan to claim the foreign earned income exclusion on a late return, see the foreign earned income exclusion tests. If your spouse is not a US person, your filing status choice is covered in married to a nonresident.
What should the Form 14653 narrative statement say?
The narrative must give specific reasons why you did not report all income, pay all tax and file all required information returns, including FBARs, and it must tell the whole story, favorable and unfavorable. The form itself says a submission without a narrative statement of facts is incomplete and does not qualify for streamlined penalty relief.
The form and IRS FAQ 6 ask you to cover:
- Your personal and financial background, and anything else that explains the failure.
- The source of the money in each foreign account or asset: inherited, opened while living abroad, or opened for a business reason.
- Your contact with each account or asset: deposits, withdrawals and investment or management decisions.
- Why you checked "no" on Schedule B, line 7a, if you or your preparer did.
- Any foreign corporation, trust or partnership you owned or controlled, why it was not reported, and your understanding of your reporting duties to the IRS and to the foreign country.
- Any professional adviser you relied on: name, address, telephone number, a summary of the advice, how you came to the adviser and how often you were in contact.
- On a joint certification, each spouse's reasons separately if they differ.
The IRS sets no length; it asks for specific reasons and a complete story. Write it so a reader who knows nothing about you can follow, account by account, how the money got there and why the filings were missed. One workable order: who you are and where you have lived; each account or asset, where its money came from and how you used it; why you did not file, including any advice you relied on; and how you learned of the duty and what you did next. You can write on the form or on a signed attachment.
Canadian RRSP and RRIF holders have extra wording to include; see catching up on missed US returns from Canada.
What else does Form 14653 ask for?
Form 14653 is a certification under penalties of perjury, not just a cover letter. Use the current revision from irs.gov; it is a fillable form that some browsers cannot display, so open it in a PDF reader.
| Part of the form | What you enter or certify |
|---|---|
| Tax and interest table | For each of the three years: the tax shown on the Form 1040 or 1040-X, the interest and the total. Your payment should equal the total. |
| Certifications | You failed to report income from a foreign financial asset, you meet the other eligibility rules, you have already e-filed any late FBARs, and the failures were non-willful. |
| Record keeping | You keep income and asset records for three years from the certification date, and foreign account records for six years if you filed late FBARs. |
| Refund warning | Asking for a refund of tax or interest you paid on omitted income, on the ground that the time limit to assess it had passed, forfeits the streamlined terms. |
| Residency | US citizens and green card holders answer yes or no for each of the three years to being physically outside the US for at least 330 full days; at least one of the three must be a "yes" year in which you also had no US abode. Joint filers whose days abroad differ show each spouse's days on the chart or in an attachment. Others attach a substantial presence test computation (the day-count test for non-citizens) covering the three years and the two before; without it the submission is incomplete and does not qualify. Whether you qualify is covered in who can use the procedures. |
| Narrative and signatures | The statement of facts, then signatures. |
Non-willful, as the form defines it, means conduct due to negligence, inadvertence or mistake, or a good-faith misunderstanding of the law. If that does not describe your case, stop before you sign: the certification is made under penalties of perjury.
The IRS's voluntary disclosure hotline answers general questions about the form at 904-661-3350, but gives no case-specific advice (FAQ 8).
Who signs Form 14653 and the returns, and what if my spouse will not sign?
You sign Form 14653 and every return. On a joint certification both spouses sign, both must meet the non-residency test, and the statements are made for both even though the form says "I". A paid preparer may sign too, but the taxpayer's signature is still required. For an estate, the executor or administrator signs as fiduciary (Form 14653).
If you filed joint returns in a covered year and your spouse or former spouse will not sign the amended joint returns or the joint Form 14653, FAQ 7 lets you sign alone, on these conditions:
- The joint amended return shows a net increase in tax. A one-signature return that shows a decrease in tax or an increase in credit is not allowed.
- Write "SFO FAQ 7" in red ink in your spouse's signature area on each amended return and on Form 14653.
- Explain in the narrative why you could not get the signature.
The IRS will routinely ask for the other spouse's signature later. If you still cannot get it, answer by referring to FAQ 7. FAQ 7 covers joint amended returns only. The IRS gives no equivalent rule for a year you never filed; see married to a nonresident and get help before choosing a filing status.
Should I file the six FBARs before I mail the package, and which late-filing reason do I choose?
File the FBARs first. Form 14653 certifies that you "have now electronically filed" any late FBARs, so they should be filed before you sign it (Form 14653).
The IRS instructions say:
- File each late FBAR electronically through the FinCEN BSA E-Filing System. FBARs are not mailed with the package.
- On the cover page, choose "Other" as the reason for filing late, then type "Streamlined Filing Compliance Procedures" in the explanation box that appears.
- Do not attach Form 14653 copies to the FBARs.
- If you cannot file electronically, contact FinCEN about alternatives.
Save each FBAR's confirmation and its BSA identifier, the tracking number FinCEN sends after filing. You need it to amend that FBAR later (FinCEN instructions).
If a preparer or your spouse e-files for you, sign FinCEN Form 114a to authorize it. You keep Form 114a; do not send it to FinCEN unless asked. Which accounts go on each FBAR, and how to find each maximum value, is covered in which accounts count on the FBAR.
Which exchange rates do I use on the returns and on the FBARs?
Returns and FBARs use different rules. Pick each one's rule and apply it the same way across all years.
| Filing | Rate rule | Source |
|---|---|---|
| Tax returns | The IRS has no official rate and generally accepts any posted rate used consistently. In general, use the spot rate when you receive, pay or accrue an item; the IRS also publishes yearly average rates. | IRS exchange rates |
| FBARs | Convert each account's maximum value at Treasury's rate for the last day of the calendar year. If Treasury has none for the currency, use another verifiable rate and state its source. Round up to the next whole dollar. | FinCEN instructions; Treasury Reporting Rates of Exchange |
| Payment | Pay the IRS in US dollars. | IRS exchange rates |
Keep a note of which rate you used for each figure. Because the rules differ, the returns and the FBARs can show different dollar amounts for money in the same account.
How do I pay the tax and interest, and what if my interest figure is wrong?
Send payment of all tax shown on the three returns plus interest on each year's late payment, with your taxpayer identification number on the check (IRS instructions). The IRS instructions describe a check in the package; they name no other payment method for a streamlined submission.
Interest runs from each year's original due date (April 15 for calendar-year filers) until you pay. The automatic two-month filing extension for people living abroad does not stop it (Publication 54). The IRS compounds interest daily at rates it sets each quarter (quarterly interest rates), so a hand calculation is easy to get wrong.
If the tax or interest is wrong, the IRS says you may receive a balance due notice or a refund (IRS instructions). The IRS describes that outcome for a miscalculation; it does not say the package loses streamlined treatment. An extra tax deficiency the IRS finds is different: it may assert penalties on that added amount.
Where do I mail the SFOP package, and can I e-file it?
Mail it on paper; the IRS does not accept electronic streamlined submissions. The IRS instructions give this address:
Internal Revenue Service, 3651 South I-H 35, Stop 6063 AUSC, Attn: Streamlined Foreign Offshore, Austin, TX 78741
The IRS says this address is only for returns filed under the procedures. Corrections go to the same mail stop with a different attention line (below). Keep a full copy of everything you send and proof of the mailing date.
The instructions do not say where the package must be mailed from. What matters is meeting the non-residency test for the covered years; if you have moved back to the US, see who can use the Streamlined Foreign Offshore Procedures.
How do a foreign pension, foreign funds or a foreign company change the package?
Each adds forms inside the package, and each needs its story in the narrative. The table shows what changes; the linked guides cover how to complete each form.
| You have | What changes in the package | Detail |
|---|---|---|
| A foreign pension or savings plan | It may need FBAR, Form 8938 or Form 3520 reporting. If you also missed a treaty deferral election, make the election with the submission and add the two statements the IRS asks for (IRS instructions). | Foreign pension reporting; for RRSPs, RRIFs and TFSAs, catching up from Canada |
| Foreign mutual funds or ETFs | Form 8621 may be required with each year's return. | PFIC filing and missed years |
| A foreign company | Form 5471, 8858 or 8865 goes inside the package. If the company is a specified foreign corporation with a transition tax inclusion, the submission must reach back to the transition-tax year and every year after, "Section 965" goes in red after "Streamlined Foreign Offshore", and the transition tax cannot be paid in installments (IRS section 965 page). | Information forms for a foreign company |
Each form must be complete for the penalty relief to hold, and a company can add years.
What happens after I mail the package: acknowledgment, transcripts and a CP11?
The IRS does not acknowledge receipt and does not sign a closing agreement; streamlined returns are processed like any other return (IRS streamlined procedures).
What to expect:
- Transcripts. An account transcript or your IRS online account may show a processed return; it can take time to appear (get transcript). For a return that does not appear, see filed return missing from IRS records; for a Form 1040-X, see amended return status.
- A CP11 or balance due notice. A CP11 means the IRS corrected one or more mistakes and the amount you owe changed. If you agree, pay by the date on the notice. If you disagree, contact the IRS by that date; after it, you lose the formal right to have the change reversed and to appeal to the Tax Court.
- A request for a spouse's signature, if you used FAQ 7.
- Audit. Returns are not audited automatically, but they can be selected like any return and checked against data from banks, financial advisers and other sources.
For an eligible filer who follows every instruction, the IRS says failure-to-file, failure-to-pay, accuracy-related, information return and FBAR penalties will not apply, unless an exam finds the original noncompliance fraudulent or the FBAR violation willful. It may still assert penalties on any additional tax deficiency it finds, and it does not remove penalties already assessed for those years (IRS instructions). A penalty notice on a streamlined year is worth reviewing against those terms before you pay or reply.
I found a mistake after mailing: how do I correct a streamlined submission?
If your streamlined returns are not under examination, send amended returns, an amended Form 14653, or both (FAQ 9):
- Write "amended" in red ink at the top of the new Form 14653.
- Write "Amended Streamlined Foreign Offshore" in red ink at the top of the first page of each corrected return.
- Explain all the facts about the error, using the same detail the original narrative needed.
- Pay any added tax and interest.
- If an FBAR was wrong, e-file an amended FBAR: check the Amend box and give the prior report's BSA identifier, or 14 zeros if you do not know it (FinCEN instructions).
The IRS's own example of an amended Form 14653 with no amended returns is a filer who reported all the income from an asset and left the asset out only of the narrative. If any income from it was missed, amended returns go with the amended form. Mail corrections to this address; it is the same mail stop as the original, with a different attention line:
IRS, 3651 S. IH 35, MS 6063 AUSC, Attn.: Streamlined Procedures, Austin, TX 78741
Where does my current-year return go, and which filings stay outside the package?
Only the three covered years go to the streamlined address. After the submission, the IRS expects you to file every later year under regular filing procedures (IRS streamlined procedures), so a return for a year outside the three is filed the normal way, on its own.
| Filing | Where it goes |
|---|---|
| The three covered years' returns and information returns | The streamlined package |
| Six late FBARs | FinCEN e-filing, before the package |
| The current year's return | Normal filing, separately |
| The current year's FBAR | Normal e-filing, due April 15 with an automatic extension to October 15 |
| A former state's return | That state's own rules: see ending state residency when moving abroad |
| Years before the covered three | Not part of the package, unless a foreign company has a section 965 inclusion (the package then starts at that year, as above); see which years SFOP covers |
Example
These examples are illustrative; all figures are in US dollars.
A single filer in Australia who never filed
A US citizen in Australia never filed a US return. She e-files six FBARs first, choosing "Other" and typing "Streamlined Filing Compliance Procedures". She then mails three Forms 1040, each with a Form 1116 because she claims a foreign tax credit, and each marked "Streamlined Foreign Offshore" in red. She includes a signed original Form 14653, a copy on each return, and one check for $1,200 of tax plus interest with her SSN on it. Her superannuation is handled as the foreign pension guide describes.
A separated couple and one signature
A couple filed joint returns for two of the three years and are now separated. One spouse will not sign the amended joint returns. The other signs alone because the amended returns show a net increase in tax, writes "SFO FAQ 7" in red in the spouse's signature area on each amended return and on Form 14653, and explains the separation in the narrative. When the IRS later asks for the second signature, the filer replies citing FAQ 7.
A forgotten account found after mailing
Two months after mailing, a filer finds a savings account that paid $300 of interest a year for each of the three years. He sends three amended returns marked "Amended Streamlined Foreign Offshore", a Form 14653 marked "amended" that explains how the account was missed, and a check for the extra tax and interest, to the corrections address. He e-files amended FBARs for the years the account should have appeared.
Different for you?
- You are not sure you qualify, or you moved back to the US: start with who can use the Streamlined Foreign Offshore Procedures.
- You are not sure your missed filings were non-willful, or the IRS has opened an exam of your returns: the procedures are closed to anyone under IRS examination, and Form 14653 is signed under penalties of perjury. Read streamlined or another route and get cross-border tax help before you sign.
- You have a foreign pension, foreign funds or a foreign company: the extra forms and years need judgment; see the foreign pension, PFIC and foreign company guides, and get cross-border tax help.
- You live in Canada with an RRSP, RRIF or TFSA: see catching up on missed US returns from Canada.
- Your spouse is not a US person or will not sign: see married to a nonresident.
- You only need the FBARs sorted: see which accounts count on the FBAR and FBAR filing help.
- You received a CP11, a balance due notice or a penalty notice on a streamlined year: get cross-border tax help before the deadline on the notice.
- You are choosing or switching preparers mid-filing: see choosing a US expat tax preparer.
Figures on this page
| Figure | Value | Source |
|---|---|---|
| FBAR filing deadline Following the calendar year reported; an automatic extension applies | April 15 | IRS: Report of Foreign Bank and Financial Accounts Checked |
| Automatic FBAR extension deadline Following the calendar year reported; no extension request is required | October 15 | IRS: Report of Foreign Bank and Financial Accounts Checked |
Primary sources
- IRS: US taxpayers residing outside the United States (Streamlined Foreign Offshore Procedures)
- IRS: Streamlined Foreign Offshore Procedures FAQs
- IRS: Streamlined filing compliance procedures
- IRS: Form 14653 (Rev. 3-2025)
- IRS: Streamlined filing compliance procedures and section 965
- IRS: Yearly average currency exchange rates
- FinCEN: BSA electronic filing requirements for the FBAR (FinCEN Form 114)
- FinCEN: Form 114a, Record of Authorization to Electronically File FBARs
- Treasury: Treasury Reporting Rates of Exchange
- IRS: Publication 54
- IRS: Quarterly interest rates
- IRS: Understanding your CP11 notice
- IRS: Get transcript
- IRS: Individual Taxpayer Identification Number
About this guide
Published by Cloud Accounting under standing professional approval. This version has no separately recorded personal review. It explains general rules for the tax year shown. It is not advice for your situation.
Changes
- : First published.