Streamlined Filing Offshore Procedures (2026) – FBAR & FATCA, Eligibility, Penalties, and Pitfalls

When a Taxpayer is a U.S. person for tax purposes and has not previously reported their foreign income on their U.S. tax returns and failed to file accurate international information reporting forms, they may be subject to extensive IRS fines and penalties. Some of the more common international reporting forms that Taxpayers may be aware of are the FBAR (FinCEN Form 114) and FATCA Form 8938 (Foreign Account Tax Compliance Act). Non-willful Taxpayers who have not yet been penalized and are not under audit may qualify for the Streamlined Filing Compliance Procedures to get into compliance and minimize or avoid penalties. The streamlined procedures have two different programs: Streamlined Domestic Offshore Procedures (SDOP) and Streamlined Foreign Offshore Procedures (SFOP). Let’s walk through the basics of both the domestic and foreign Streamlined Filing Compliance (Offshore) Procedures.