Streamlined Domestic Offshore Procedure

This program is designed primarily for U.S. citizens and residents living in the U.S. who non-willfully failed to report their foreign income or assets; i.e. they weren’t aware of their U.S. tax compliance requirements, misunderstood the law or got bad advice.




  • Your failure to comply was non-willful
  • You no not meet non-residency requirement (330 days outside the U.S. in one of the last 3 delinquent tax years)
  • You filed original tax returns for the previous 3 years
  • You failed to report and pay tax on income from a foreign financial asset
  • You are not under civil examination or criminal investigation by the IRS




  • File up to 3 years amended tax returns
  • File up to 6 years FBARs
  • Pay back taxes and interest
  • Sign certification of non-willfulness along with an explanation of the facts surrounding your non-compliance
  • Pay a 5% penalty based on highest value of your unreported the assets


In exchange for taking part in the Streamlined Domestic Offshore Procedure any non-compliance older than the years covered is forgiven.

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