Can I use streamlined procedures if I knew about the filing requirement?

No. Both programs require a certification that your non-compliance was non-willful — meaning you didn't know about the requirement or made an honest mistake. If you knowingly failed to file, you may need the IRS Voluntary Disclosure Program instead.

How many years of tax returns do I need to file?

Both programs require amending or filing 3 years of US tax returns and 6 years of FBARs (FinCEN 114).

All Comparisons

Comparison Guide

Streamlined Domestic vs Streamlined Foreign Offshore

Which IRS Amnesty Program is Right for You?

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Streamlined Domestic Offshore (SDOP)Option A

For US taxpayers who were living in the United States during the compliance period

Advantages

Resolves years of non-willful non-compliance
Reduces penalties to 5% of highest aggregate foreign account balance
No risk of criminal prosecution for non-willful violations
Can amend up to 3 years of tax returns and 6 years of FBARs

Disadvantages

Still requires payment of 5% miscellaneous offshore penalty
Not available for willful violations — those require OVDP or similar
Must certify non-willfulness under penalty of perjury
Available only to US residents (not expats living abroad)

Best For

• US-based taxpayers who have foreign accounts or income they failed to report due to non-willful conduct

Typical Cost:

Streamlined Foreign Offshore (SFOP)Option B

For US taxpayers who were living outside the US during the compliance period

Advantages

Zero penalty — no offshore penalty for eligible expats
Resolves non-willful non-compliance for expats
File 3 years of amended returns + 6 years of FBARs
No criminal prosecution exposure for non-willful violations

Disadvantages

Must meet the non-residency requirement (330 days outside US in at least 1 of 3 years)
Cannot be used if prior IRS examination is underway
Must certify non-willfulness — willful violations excluded
Does not cover state tax non-compliance

Best For

• US expats who lived abroad and failed to file taxes or report foreign accounts due to non-willful reasons

Typical Cost:

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Our Verdict

Choose Streamlined Domestic Offshore (SDOP) if:

Choose Streamlined Foreign Offshore (SFOP) if:

Frequently Asked Questions

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