Do I Qualify for Streamlined Filing?
Answer 7 quick questions to find out which IRS compliance program fits your situation. Takes about 2 minutes. Your answers are not stored or shared.
What is your U.S. tax status?
The IRS Streamlined Procedures are available to U.S. persons: citizens, green card holders, and those who meet the substantial presence test.
Have you lived outside the U.S. for at least 330 days in any of the last 3 tax years?
This determines whether you may qualify for the foreign (SFOP) or domestic (SDOP) version of the Streamlined Procedures. The 330-day threshold follows the IRS physical presence test.
Was your failure to file or report due to willful conduct?
The Streamlined Procedures require that your failure to report foreign financial assets, pay all tax due, and submit all required information returns was due to non-willful conduct. Willful conduct means a voluntary, intentional violation of a known legal duty.
Do you have unfiled FBARs or other foreign account/asset reporting?
This includes FinCEN Form 114 (FBAR), Form 8938 (FATCA), Form 3520 (foreign trusts or gifts), Form 5471 (foreign corporations), or other international information returns.
Do you have unfiled or amended U.S. tax returns that need to be submitted?
Under the Streamlined Procedures, you may need to file or amend the most recent 3 years of income tax returns (or more, depending on the program).
Are you currently under IRS examination, audit, or criminal investigation?
If the IRS has already initiated a civil examination or criminal investigation related to your tax returns or foreign accounts, you may not be eligible for the Streamlined Procedures.
Have you previously made a voluntary disclosure to the IRS?
If you participated in a prior IRS voluntary disclosure program (such as the now-closed OVDP) or made a prior Streamlined Filing submission, this may affect your eligibility.
Streamlined Foreign Offshore Procedures (SFOP)
Based on your answers, you may qualify for SFOP. This is the best possible outcome: qualifying filers living abroad pay zero offshore penalty. You will need to file the most recent 3 years of income tax returns (original or amended) and 6 years of FBARs, along with a certification statement explaining your non-willful conduct.
How It Works
- Book a free 15-minute triage call to confirm your eligibility and review your situation
- Receive a written $750 analysis memo (credited in full toward your engagement fee)
- Qorri Tax prepares 3 years of tax returns, 6 years of FBARs, and all required international forms
- You sign and review a non-willful certification statement
- Everything is filed together with the IRS. No separate penalty payment required for SFOP filers
Streamlined Domestic Offshore Procedures (SDOP)
Based on your answers, you may qualify for SDOP. This program is designed for U.S. residents who have unreported foreign accounts or income. There is a one-time miscellaneous offshore penalty of 5% of the highest aggregate balance of your unreported foreign financial assets during the covered years. This is significantly lower than the penalties that could otherwise apply.
How It Works
- Book a free 15-minute triage call to confirm your eligibility and review your situation
- Receive a written $750 analysis memo (credited in full toward your engagement fee)
- Qorri Tax prepares 3 years of amended returns, 6 years of FBARs, and all required international forms
- The 5% miscellaneous offshore penalty is calculated based on your highest aggregate unreported foreign asset balance
- You sign and review a non-willful certification statement
- Everything is filed together with the IRS along with the penalty payment
Delinquent FBAR or International Information Return Submission
Based on your answers, the full Streamlined Procedures may not be necessary. If you have delinquent FBARs or information returns but your tax returns are filed and accurate, the IRS offers delinquent submission procedures that allow you to file late international returns without penalty in many cases, provided you have reasonable cause for the late filing and have not been contacted by the IRS about the delinquent returns.
How It Works
- Book a free 15-minute triage call to confirm whether delinquent submission procedures apply to your situation
- Qorri Tax reviews which international returns are delinquent (FBAR, Form 8938, Form 5471, Form 3520, etc.)
- Late returns are prepared with a reasonable cause statement attached
- Returns are filed with the IRS. In most cases, no penalty applies if you have reasonable cause and have not been contacted
Your Situation Needs a Personalized Review
Based on your answers, your situation may involve factors that require a more detailed analysis before determining the right compliance path. This is not uncommon, and it does not necessarily mean you are disqualified from the Streamlined Procedures. A short consultation can clarify your options and map out the best path forward.
What Happens Next
- Book a free, confidential 15-minute triage call with Tajma Qorri
- Discuss your specific facts. Every situation is different, and the right approach depends on your particular circumstances
- Receive a clear recommendation on which IRS program applies or whether a different compliance strategy is appropriate
- If you decide to move forward, a written $750 analysis memo is the next step, credited in full toward any engagement
