STREAMLINED FILING COMPLIANCE

Procedures

For those who have not timely filed their U.S. Federal income tax returns or FinCEN Form 114, the IRS allows to come clean by participating in the Streamlined Filing Compliance Procedures.

The modified streamlined filing compliance procedures are designed only for individual taxpayers, including estates of individual taxpayers. The streamlined procedures are available for both U.S. individual taxpayers residing outside the United States and U.S. individual taxpayers residing in the United States. In those cases, the review will be expedited and the IRS will not assert penalties or pursue follow-up actions.

If you want to make use of the Streamlined Filing Compliance Procedures, you should file the following:

delinquent tax returns, with appropriate related information returns (e.g., Form 3520 or 5471), for the past three years

delinquent FBARs (FinCEN Form 114) for the past six year

Certification by U.S. Person Residing Outside of the United States for Streamlined Foreign Offshore Procedures

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Once a taxpayer makes a submission under the Streamlined Filing Compliance Procedures, the Offshore voluntary disclosure incentive program (OVDI) is no longer available. It should also be noted that if you are ineligible to use the OVDI you are also ineligible to participate in the Streamlined Filing Compliance Procedures.