What is the Streamlined Foreign Offshore Procedure and how does it differ from the domestic version?
The IRS Streamlined Filing Compliance Procedures let taxpayers who non-willfully failed to report foreign accounts and income catch up by filing amended returns, delinquent FBARs, and a certification of non-willful conduct. There are two tracks. The Streamlined Foreign Offshore Procedures, for those who meet a non-residency requirement, waive the miscellaneous offshore penalty entirely, so eligible expats pay only back tax and interest. The Streamlined Domestic Offshore Procedures, for U.S.-resident taxpayers, impose a 5% penalty on the highest aggregate value of the unreported foreign assets. Both require genuine non-willfulness; if your conduct was willful, these programs are not appropriate and could increase your exposure. This is a valuable path for immigrants who did not know the rules, but the certification is signed under penalty of perjury, so get professional guidance. See irs.gov.
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