Streamlined Foreign Offshore Procedures:
Who Qualifies and How to File

Yes, in most cases. The US taxes its citizens and green card holders on worldwide income, wherever they live. If your income is above the US filing threshold, you’ll need to file a US return each year, even if you also pay UK tax. The good news is that tools like the Foreign Tax Credit, the Foreign Earned Income Exclusion and the US-UK tax treaty mean many UK-based Americans owe little or no US tax. They still need to file.

First, please don’t panic. This is very common, and there is a clear path back to compliance. Most Americans in the UK who missed filings unintentionally can use the Streamlined Procedures, which usually involve filing three years of returns and six years of FBARs, with no late-filing penalties. The most important step is to act before the IRS contacts you. We’ll start with a free eligibility check and talk you through your options, with no judgment.

It’s an IRS program for Americans living abroad who missed US filings by mistake. You generally qualify if, in at least one of the three most recent tax years with a filing deadline that has passed, you had no US home (abode) and were outside the US for at least 330 full days, and your original failure to file was non-willful. You also need a valid SSN or ITIN, and you must not already be under IRS examination for those years. If you’re unsure, we’ll assess it with you.

Our starting fee for a complete Streamlined submission is £1,750, with no hidden extras. That includes three years of returns, six years of FBARs, and a certification statement. Preparation typically takes 3-4 weeks once we have your documents. After submission, the IRS works to its own timeline, and there is no fixed processing time.

Streamlined is for people whose missed filings were non-willful, meaning honest mistakes or not knowing the rules. For those living abroad, it carries no failure-to-file, accuracy, information-return or FBAR penalties, only the tax and interest owed. The Voluntary Disclosure Program is for willful or higher-risk cases, and it involves penalties and closer scrutiny. Most Americans we meet in the UK fit Streamlined. If your situation looks more complicated, we’ll tell you honestly and explain the next step.

An FBAR (FinCEN Form 114) is a report of your foreign financial accounts. You must file one if the combined value of all your foreign accounts exceeded $10,000 at any point in the year. The due date is April 15, with an automatic extension to October 15. It’s filed separately from your tax return, which is a common source of confusion. Missing FBARs is one of the main reasons people need Streamlined Procedures.

They can, and this is one of the most common traps. ISAs are tax-free in the UK but not in the US, so income and gains inside them are generally reportable. Many UK funds and ETFs held in ISAs are treated by the US as PFICs, which come with complex reporting. UK pensions are often treated more favorably under the US-UK treaty, but this depends on the type of scheme. We’ll review each account and keep it as simple as possible.

Often not, or very little. The Foreign Tax Credit lets you offset US tax with the UK tax you’ve paid, and the Foreign Earned Income Exclusion may reduce your US income further. Because UK rates are generally similar to or higher than US rates on earned income, many clients owe nothing. Some income, such as investment income, gains and certain pension payments, can still create a US bill, so we’ll check each year.

Penalties can be significant, especially for unreported accounts, but most people who come forward voluntarily and fix things through the right program are treated reasonably. The risk grows if the IRS contacts you first, which is why acting early matters. If you missed filings by mistake, there’s usually a way back without penalties. We’ll look at your situation calmly and explain exactly where you stand.

US citizens need an SSN to file. If you’ve lost yours or never had one, we can guide you through requesting it from the Social Security Administration, including from the UK. A non-citizen spouse can usually get an ITIN, which is an alternative taxpayer ID. A valid SSN or ITIN is also required to use the Streamlined Procedures, so we’ll sort this out at the start.