For US citizens and green card holders who fell behind
Streamlined Filing Service: Catch Up on US Returns and FBARs
Streamlined for Americans in Canada who never filed, including your Canadian corporation (Form 5471), RRSPs, TFSAs and ETFs, with one CPA licensed in BC and Washington. The IRS Streamlined procedures let you catch up with 3 years of returns and 6 years of FBARs. Gurleen Kaur, CPA licensed in Washington State (#41150) and British Columbia, prepares and signs the returns, and prepares the certification for you to review and sign. Fixed fee, quoted in writing before we start. Based in Surrey, working with clients across Greater Vancouver, the rest of Canada and remotely.
Quick answer
What does a Streamlined filing include?
For someone living outside the US, the IRS Streamlined Foreign Offshore procedure means the most recent 3 years of US returns with any required information returns, the most recent 6 years of FBARs, payment of any tax and interest, and a signed Form 14653 certifying the failure was non-willful (IRS). If every instruction is followed, the IRS says no failure-to-file, failure-to-pay, accuracy, information return or FBAR penalties apply. US residents use the Domestic version, which has a 5% penalty (IRS).
At a glance
- Who it suits
- US citizens and green card holders whose failure was non-willful
- Most common case
- Americans in Canada who never filed US returns or FBARs
- What you file
- 3 years of returns, 6 years of FBARs, one certification
- Who signs
- Gurleen prepares and signs the returns; you sign the certification
- Source
- IRS, checked November 7, 2026
Who qualifies
The IRS describes non-willful conduct as "negligence, inadvertence, or mistake or conduct that is the result of a good faith misunderstanding of the requirements of the law" (IRS). You cannot use Streamlined if the IRS has already started a civil examination of any of your returns, or a criminal investigation, and US citizens need a valid Social Security Number. Penalties already assessed are not removed.
A common case: a US citizen who has lived in Canada for years, filed Canadian returns every year, and never knew about US filing. Check yourself with our Streamlined eligibility checker, or read whether there is an IRS amnesty for missed FBARs.
Foreign Offshore or Domestic Offshore
Which procedure applies depends on where you lived, not where your money is.
| Streamlined Foreign Offshore | Streamlined Domestic Offshore | |
|---|---|---|
| Who it is for | US citizens and green card holders living outside the US, such as Americans in Canada | US residents who have filed their US returns but left out foreign income or accounts |
| Residence test | In at least one of the last 3 years: no US abode and at least 330 full days outside the US | Does not meet the outside-the-US test |
| US returns | The most recent 3 years, late or amended, with required information returns | Amended returns for the most recent 3 years, with required information returns |
| FBARs | The most recent 6 years | The most recent 6 years |
| Certification | Form 14653, signed by you | Form 14654, signed by you |
| Penalty | No failure-to-file, failure-to-pay, accuracy, information return or FBAR penalties if every instruction is followed | A 5% miscellaneous offshore penalty |
What is included
- US returns: the most recent 3 years of Form 1040, with the information returns your situation needs, such as Form 8938, Form 5471 for a Canadian corporation you own, or Form 8621 for funds and ETFs.
- FBARs: the most recent 6 years, filed with FinCEN.
- The certification: Form 14653 (outside the US) or 14654 (in the US). See your non-willful statement below.
- The filing package: marked as Streamlined as the IRS instructions require, with the tax and interest worked out so you know what to pay.
- A fixed fee, quoted in writing before we start. No hourly billing.
From US$1,850 for a simple Streamlined Foreign Offshore filing: 3 federal returns, 6 years of FBARs and your non-willful statement. Form 5471, Form 8621 and other forms you need are added to the same fixed written quote after review. State returns are not included.
Your non-willful statement
On Form 14653 or 14654 you certify three things: that you are eligible for the procedure, that all required FBARs have now been filed, and that your failure to file returns, report income, pay tax and file information returns, including FBARs, resulted from non-willful conduct (IRS). The IRS defines non-willful conduct as "negligence, inadvertence, or mistake or conduct that is the result of a good faith misunderstanding of the requirements of the law" (IRS).
We draft the statement from your facts and documents: where you lived, what accounts and income you had, what you knew, and how you found out. You review it, correct anything that is not exactly right, and sign it, because it is your statement to the IRS and it is made under penalties of perjury.
How the 5% Domestic Offshore penalty is calculated
The penalty applies only under Streamlined Domestic Offshore. The IRS works it out by totalling the year-end balances or values of the foreign financial assets subject to the penalty for each year in the covered tax return period and the covered FBAR period, and taking the highest of those yearly totals (IRS). The penalty is 5% of that highest total.
An asset counts in a given year if, as the IRS describes it:
- it should have been reported on an FBAR for that year and was not, or
- it should have been reported on Form 8938 for that year and was not, or
- it was reported, but income from it was not reported that year.
Under Streamlined Foreign Offshore there is no such penalty.
Own a Canadian corporation?
Then your catch-up usually includes Form 5471 for the company as well. We give you one fixed written quote for the whole catch-up: 3 years of returns, 6 years of FBARs, Form 5471 for each year, and Form 8621 for Canadian funds if required. The matching Canadian T1 and T2 can be prepared by the same CPA, so both countries see the same facts. See our Form 5471 filing service and US citizens owning a Canadian company.
Why US citizens in Canada choose us
- Licensed on both sides: Gurleen Kaur is a CPA licensed in British Columbia and in Washington State (#41150).
- Canadian items in the same engagement: RRSPs, TFSAs, CPP and OAS, and a Canadian corporation you own (Form 5471) are handled together with your US returns, not passed to someone else.
- Your Canadian return too, if you need it: Gurleen also prepares the Canadian T1, so the same facts are reported the same way in both countries.
Canadian items that often come up
- RRSP and RRIF accounts. The IRS says Form 8891 is no longer required for relevant Canadian plans (IRS).
- TFSAs and Canadian mutual funds and ETFs
- CPP, OAS and other pensions
- A Canadian corporation you own (Form 5471)
- FBAR and T1135 for the same accounts
Gurleen also prepares Canadian T1 and T2 returns, so both sides of the same facts line up.
What we need from you
- Your Canadian returns and notices of assessment for the years involved
- Year-end statements for every bank, investment and registered account outside the US, with the highest balance if you have it
- Pension, CPP and OAS slips, and details of any company you own
- Any US returns or FBARs you have already filed, and any IRS letters
- Your Social Security Number
Do not send tax IDs or statements through the website form. We agree how to share documents once you accept the quote.
How it works
- Request a quote. Tell us where you lived, how many years are open and what accounts you have
- Records review and fixed quote. You send the documents; you get a written scope and fee
- Preparation and review. We prepare the returns, FBARs and draft certification, and review them with you
- Filing. You sign the certification; we file the package the way the IRS instructions set out
Common questions
Can I use Streamlined if I never filed US returns at all?
If you live outside the US and meet the 330-day test, yes: the Foreign Offshore procedure takes late original returns. The Domestic procedure requires that you already filed US returns for the 3 years.
How many years do I have to file?
The most recent 3 years of US returns whose due date has passed, and the most recent 6 years of FBARs.
Will I pay a penalty?
Under Streamlined Foreign Offshore, the IRS says no failure-to-file, failure-to-pay, accuracy, information return or FBAR penalties apply if every instruction is followed. Streamlined Domestic has a 5% miscellaneous offshore penalty. Tax and interest are still paid.
Who signs Form 14653?
You do. It is your certification that the failure was non-willful. We draft it from your facts and you review it before signing.
What if the IRS has already contacted me?
If the IRS has started a civil examination of any of your returns, you cannot use Streamlined. Tell us what the letter says and we will look at other options.
Will the IRS confirm my Streamlined submission was accepted?
No. The IRS says Streamlined returns are processed like any other return, receipt is not acknowledged, and there is no closing agreement. The returns are not audited automatically, but they can be selected for audit like any other return.
Does Streamlined cover my state tax returns?
The IRS Streamlined procedures are for your federal US returns and FBARs. State returns are a separate question that depends on whether you had a filing requirement in a state, and we review it as part of the quote.
How is the fee charged?
As a fixed fee, quoted in writing after we review your situation and documents, and before any work starts. There is no hourly billing.
Do you also do my Canadian return?
Yes. Gurleen Kaur, CPA, prepares Canadian T1 and T2 returns as well as US returns.
Sources
Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.
- IRS: Streamlined filing compliance procedures
- IRS: US taxpayers residing outside the United States (Streamlined Foreign Offshore)
- IRS: US taxpayers residing in the United States (Streamlined Domestic Offshore)
Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated November 7, 2026. This page is general information, not tax or legal advice for your situation.
Related guides: Is there an IRS amnesty?, Streamlined eligibility checker, Behind on US filings, Quiet disclosure vs Streamlined.
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Prepared and signed by a licensed US CPA who can represent you before the IRS. Verify Gurleen Kaur's Washington licence (#41150) on CPAverify