Part of the U.S. Expat Tax Series by Tax.Travel

This article is part of Antravia’s U.S. Expat Tax Series - a collection of practical guides for Americans living or working abroad. Whether you’re a long-term expat, digital nomad, or remote entrepreneur, these resources explain how to stay compliant with the IRS while reducing double taxation and managing your finances internationally.

Streamlined Filing for U.S. Expats: Catch up on missed Tax Returns in 2025

By Antravia
Published: November 16, 2025
antravia.com

For Americans living abroad, U.S. tax obligations do not disappear when you relocate. The IRS still expects annual tax returns and foreign bank account reporting, regardless of where you live or where your income is earned. When returns are missed for several years, many expats assume penalties are unavoidable. In reality, the IRS Streamlined Filing Compliance Procedures allow eligible taxpayers to catch up without penalties if their non-compliance was non-wilful.

This 2025 guide explains the current eligibility rules, the required filings, and the practical steps involved. It is written for expats who want clarity and a clean path forward without unnecessary technical jargon.

1. Understanding Whether you Qualify for Streamlined Filing

The IRS frequently refines its rules, providing clarity around what “non-wilful” behaviour looks like, but the core principle remains consistent. At its core, non-wilful means that the failure to file or report foreign accounts was the result of oversight, misunderstanding, or reasonable cause, and not intentional avoidance.

There are two versions of the streamlined program:

Streamlined Domestic Offshore Procedures (SDOP)
This applies to individuals living in the United States who failed to file foreign income or asset reporting. These taxpayers must certify that their failure was non-wilful and pay a small offshore penalty. Domestic residents generally qualify only when the total tax due for each of the three covered years is modest.

Streamlined Foreign Offshore Procedures (SFOP)
This is intended for individuals who genuinely live abroad. To qualify, you must meet the physical presence test or demonstrate that your main residence has been outside the United States for the full relevant period. SFOP is more generous because it eliminates all penalties if the IRS accepts the certification of non-wilfulness.

Expats should review the IRS “Reasonable Cause Assistant” and Publication 5569 before filing. These tools help determine whether your circumstances align with the non-wilful standard.

2. What must be Filed in 2025–2026

Streamlined Filing requires all missing tax returns and foreign account reports to be submitted together. It is not a piecemeal process. To be compliant, you must provide:

Three Years of U.S. Tax Returns (Form 1040)
The IRS requires the most recent three years of complete federal tax returns. These may be original returns if you never filed, or amended returns if the IRS already has partial filings. For 2025 streamlined submissions, the deadline to complete these returns is the standard 2025-2026 filing window, but most taxpayers finish the return package well before April 15, 2026.

Six Years of FBARs (Foreign Bank Account Reports)
FBARs are submitted electronically through FinCEN’s BSA e-filing system. These cover the six most recent calendar years in which foreign accounts exceeded $10,000 at any point.

A Signed Certification of Non-Wilful Conduct
This certification is the heart of the process. Foreign residents use Form 14653 and domestic residents use Form 14654. The form explains why deadlines were missed and confirms that there was no intentional avoidance.

Payment of Any Tax Due
Any outstanding tax identified in the three years of returns must be paid at submission. Payments can be made electronically through EFTPS or by cheque.

A useful practical tip is to file your FBARs first. The IRS and FinCEN systems match data during processing, and having the FBARs already in the system can prevent delays.

3. Step-by-Step Filing Process

Step 1: Collect Documentation
Gather W-2s, 1099s, foreign payslips, investment statements, and all foreign bank records for the relevant years. Foreign currency amounts must be converted to U.S. dollars using the Treasury’s annual exchange rates.

Step 2: Prepare the Three Years of 1040s
These must include all worldwide income. Many expats rely on the Foreign Earned Income Exclusion (Form 2555) or the Foreign Tax Credit (Form 1116) to reduce double taxation. If you previously filed incomplete returns, these will be amended using Form 1040-X.

Step 3: File the Six Years of FBARs
These are submitted online directly to FinCEN. Make sure all accounts are listed, including joint accounts, investment accounts, pension accounts, and any foreign accounts you have signature authority over.

Step 4: Prepare and Sign the Non-Wilful Certification
Form 14653 (for foreign residents) must be signed under penalty of perjury. It is crucial that the explanation is truthful and detailed, focusing on the facts that led to non-compliance.

Step 5: Mail the Complete Streamlined Package
Foreign offshore submissions still go to the IRS processing centre in Austin, Texas. The package includes the returns, the certification, and proof of tax payment.

4. Common Mistakes and how to avoid them

Filing the returns but forgetting the FBARs
Many taxpayers assume the 1040 is enough. It is not. Missing FBARs can trigger penalties even when the streamlined process is used.

Attempting to amend an old 1040 to add the Foreign Earned Income Exclusion
The FEIE generally cannot be applied for the first time on an amended return unless you follow specific procedures. Streamlined Filing avoids this problem because you are filing the entire return package at once.

Sending documents to the wrong IRS address
Streamlined submissions that are mailed to the wrong office can sit untouched for a year or longer. Always use the official Austin address specified in the instructions.

A recent Antravia case involved a U.S. expat living in Dubai who had not filed in six years. With the correct streamlined approach, the individual avoided all penalties and recovered more than $18,000 in overpaid U.S. withholdings.

5. A Simple 2025 Expat Tax Calendar

December 2025
Collect all foreign bank statements, convert balances using Treasury rates, and confirm account lists for FBARs.

January 2026
Prepare draft Forms 1040 and 2555 or 1116 for the three relevant tax years.

March 2026
Submit FBARs through the FinCEN portal. Early filing helps reduce processing delays.

April 2026
Mail the streamlined return package, the certification form, and payment for any tax due.

Looking for more expat tax guidance? Visit tax.travel/us-expats for detailed resources on filing from abroad, FBAR and FATCA rules, and other essentials for U.S. citizens overseas.

Need help with your U.S. taxes abroad?

Antravia supports American expats, freelancers, and digital nomads with expert tax and accounting guidance. We help you file accurately, claim the right exclusions, and stay compliant wherever you live.

Talk to Antravia →

References

• IRS Rev. Proc. 2025-10 www.irs.gov/pub/irs-drop/rp-25-10.pdf

• IRS Pub 5569 (Reasonable Cause) www.irs.gov/publications/p5569

• Treasury Exchange Rates fiscal.treasury.gov/reports-statements/treasury-reporting-rates-exchange.html

• FinCEN BSA E-Filing bsaefiling.fincen.treas.gov

• Form 2555 Instructions (2025) www.irs.gov/instructions/i2555

Disclaimer:
Content published by Antravia is provided for informational purposes only and reflects research, industry analysis, and our professional perspective. It does not constitute legal, tax, or accounting advice. Regulations vary by jurisdiction, and individual circumstances differ. Readers should seek advice from a qualified professional before making decisions that could affect their business.
See also our Disclaimer page