Late Filing & Compliance

Streamlined Filing Compliance Procedures

The IRS's safe-harbour catch-up programme for non-wilful late filers living abroad. Three years of returns, six years of FBARs.

Late Filing & Compliance
Overview

Why this filing matters

The IRS's safe-harbour catch-up programme for non-wilful late filers living abroad. Three years of returns, six years of FBARs.

Note — Catch-up for non-wilful late filers.

Who this is for

  • Americans abroad who haven't filed US returns for multiple years
  • Clients with unreported UK accounts but no wilful conduct

What you get

  • Non-wilfulness assessment
  • Three years of amended/original 1040 returns
  • Six years of FBARs
  • Certification letter (Form 14653) preparation
Our approach

Built for the cross-border edge cases.

Most US-UK filings fail the same way: a treaty position that wasn’t disclosed, a foreign account that slipped under FBAR thresholds, a PFIC election filed in the wrong year, a carry-forward not tracked from one preparer to the next. The cost of any single one of those is rarely catastrophic on its own — it’s the compounding over multiple filing seasons that quietly turns a clean tax life into a six-figure remediation project.

We start every engagement by looking at the edge cases first — the elections, the disclosures, the carry-forwards, the side-effects on next year’s return — and only then turn to the routine line items. The result is a filing that reads cleanly to anyone who picks it up next: another preparer, the IRS, or a successor in your own business.

  • Position memo on every meaningful election, with the reasoning written down for the next return
  • Carry-forwards (FTC, capital losses, PFIC basis) tracked year-on-year so nothing expires unused
  • Plain-English commentary on every position taken — the kind that makes a future audit a non-event
Reviewing IRS notices and prior-year returns
Our process

How we handle your streamlined filing compliance procedures

Four steps from first call to filed return. Fixed fee confirmed before any work begins.

  1. 01

    Intake

    30-minute scoping call. We confirm your situation, required filings, and send a tailored document list.

  2. 02

    Review

    We analyse your position, flag any cross-border risks, and confirm the scope and fee before any work starts.

  3. 03

    Prepare

    Draft returns and schedules are prepared with plain-English commentary on key positions for your review.

  4. 04

    File

    E-file with the IRS / FinCEN, send confirmations, and handle any follow-up notices or questions.

Pricing

Fixed fees — no surprises

Streamlined SFOP packages start from £1,800 + VAT — covers three years of 1040s, six years of FBARs, and the Form 14653 narrative. Fee scales with return complexity and number of accounts; quoted after intake.

FAQs

Common questions about Streamlined Filing Compliance Procedures

Am I eligible for Streamlined from the UK?
Yes, provided you were outside the US for at least 330 days in one of the last three years and your conduct was non-wilful. The Domestic variant (SDOP) has different rules and limited penalty protection.
What does 'non-wilful' actually mean?
Honest misunderstanding, negligence, or mistake — not intentional evasion. Your Form 14653 narrative must set this out credibly. We draft it with you based on your facts; it's the critical document in the package.
Do I pay penalties under Streamlined?
No failure-to-file, failure-to-pay, or FBAR penalties under the offshore Streamlined (SFOP). You pay tax plus interest on the three years of returns — but no penalties, provided the non-wilfulness certification stands.
What if the IRS disagrees with my non-wilful claim?
Rare, but possible. If challenged, we handle the correspondence and — where appropriate — appeal or defend the position. A well-drafted Form 14653 narrative significantly reduces the risk of pushback.
How long does the whole process take?
Typically 8–12 weeks to prepare, then the IRS takes 6–12 months to process and close. You're compliant from the date of filing, not the date of closure.

Ready to get this filed?

Tell us your situation and we'll confirm scope, a fixed fee, and the documents we need — usually within one business day.