US Streamlined Tax Returns for Americans in the UK
Behind on your US tax returns while living in the UK?
If you're a US citizen or Green Card holder living in the UK and have fallen behind with your US tax filing obligations, you may be able to use the IRS Streamlined Foreign Offshore Procedures also known as the US tax amnesty for Americans living abroad. This procedure bring your US tax affairs up to date. Phinch are a UK-based tax firm specialising in US tax compliance for Americans living in the UK. We can assess whether the Streamlined Procedures may be appropriate for you and prepare the required US tax returns, information reporting and FBAR filings.
What are the Streamlined Procedures?
The IRS Streamlined Filing Compliance Procedures are a set of programs created by the Internal Revenue Service (IRS) to help taxpayers who failed to report foreign income or assets come back into compliance - without facing the full penalties that would normally apply.
They’re designed for people who:
- Didn’t report foreign income, or
- Failed to file required international forms (eg. FBARs)
- But whose failure was non-willful (eg. due to mistake, negligence, or misunderstanding).
What does Streamline Submission Involve?
For US citizens living in the UK who have fallen behind with their US tax filing obligations, the IRS Streamlined Foreign Offshore Procedures may provide a way to bring your tax affairs up to date.
Typically, the process involves:
- Three years of US tax returns – preparing and filing your most recent three years of outstanding US federal tax returns, together with any required forms and schedules.
- Six years of FBARs – preparing and filing FBARs (FinCEN Form 114) where required to report qualifying foreign financial accounts.
- Certification of non-willfulness – completing Form 14653, confirming that your failure to report your income and foreign financial assets was due to non-willful conduct.
- Review of your UK and US tax position – considering how your UK income, pensions, investments, property and other financial interests may need to be reported for US tax purposes.
- Bringing your US tax affairs up to date – helping you establish ongoing US tax compliance once the Streamlined process has been completed.
The Streamlined Procedures are subject to specific eligibility requirements, so they are not suitable for everyone. Phinch can review your circumstances and explain whether the procedure may be appropriate for you.
Who Can Use the Streamlined Foreign Offshore Procedure?
The Streamlined Foreign Offshore Procedures are designed for eligible US taxpayers who live outside the United States and have failed to meet certain US tax filing or reporting requirements due to non-willful conduct.
For example, the procedure may be relevant if you are a US citizen or Green Card holder living in the UK and:
- You have never filed a US tax return, despite being required to do so.
- You have missed US tax returns for several years.
- You have not reported certain foreign income or financial assets to the IRS.
- You were unaware that living in the UK does not generally remove your US tax filing obligations.
- You were unaware of the US reporting requirements that can apply to UK bank accounts, investments, pensions or other foreign financial interests.
- Your failure to file or report was non-willful, meaning it was due to factors such as a mistake, negligence, misunderstanding or lack of awareness rather than a deliberate attempt to avoid your US tax obligations.
Eligibility depends on your individual circumstances and the IRS requirements for the Streamlined Foreign Offshore Procedures. Simply living outside the US or being behind with your tax returns does not automatically mean that you qualify.
If you would like to confirm whether you are eligible, Phinch can review your circumstances during a call and explain the options available to you.
Yes, potentially, if the IRS eligibility requirements are met.
One of the benefits of the Streamlined Foreign Offshore Procedures is that eligible taxpayers who successfully comply with the requirements are generally not subject to failure-to-file, failure-to-pay, accuracy-related, certain information-return or FBAR penalties relating to the returns and filings submitted under the procedures.
The IRS don't expect you to file a lifetime of US tax returns. Under the Foreign Offshore Procedures, eligible taxpayers generally file delinquent US tax returns for the most recent three years for which the filing deadline has passed, together with any required international information returns and must also file any required FBARs for the most recent six years.
You may have US tax to pay. The Streamlined Foreign Offshore Procedures do not mean that any US tax due is automatically waived. Eligible taxpayers must pay the tax and applicable interest due in connection with the returns they submit. However, if the requirements of the Streamlined Foreign Offshore Procedures are met, taxpayers are generally not subject to failure-to-file, failure-to-pay, accuracy-related, certain information-return and FBAR penalties covered by the procedure.
Becoming compliant through the Streamlined Procedures is not a one-off filing exercise. You will generally need to continue filing US tax returns and FBARs where required.
There is currently no specific deadline for eligible taxpayers to make a submission under the Streamlined Foreign Offshore Procedures. But the IRS states that the procedures can be changed or terminated at any time. If you become aware that you have US tax filing or reporting obligations that you have not met, it is therefore sensible to address your position at the earliest opportunity rather than continue to leave your affairs unresolved.
Paying tax in the UK does not generally remove your US tax filing obligations. US citizens and Green Card holders living in the UK are still required to file a US tax return and report certain foreign income and financial assets to the IRS.
Yes. Phinch can support eligible US citizens and Green Card holders living in the UK with the Streamlined Foreign Offshore Procedures. We can assess your circumstances, prepare the required US tax returns, FBARs and information reporting, and guide you through the process of bringing your US tax affairs up to date. If you think you may need to file under the Streamlined Procedures, book a call with Phinch to discuss your circumstances.
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Mike Herford
Phinch is a fantastic company. Especially David Parmenter and Sebastian Hassan-Ally who are responsive, proactive and very good at what they do. I am very pleased I engaged this team.
Paul Hemmings
[The Phinch] team did a great job: fantastic communication and follow-up throughout the filing process. Highly recommended!
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Rahul Moodgal
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Jane Jarzebowski
My husband & I returned to the UK after a long period of living abroad. Phinch were highly recommended to us as a business that was both professional and compassionate. We have received excellent advice & support from everyone who has helped us and we continue to do so. Thank you so much to you all.
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