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Which IRS catch-up route applies to you?

Seven questions against the published IRS eligibility conditions. You get the route, the reasoning, the covered years and the penalty position — not a sales pitch.

Question 1 of 6

Are you a US citizen or green card holder?

How the screening works

It tests the blocking conditions first

An open civil examination for any taxable year, or an IRS Criminal Investigation, makes a taxpayer ineligible for Streamlined whatever else is true. The screener checks that before it looks at residence.

Then non-willfulness

Streamlined rests on a signed certification of non-willful conduct. If the failure was willful, the route is the CI Voluntary Disclosure Practice, not Streamlined.

Then the lighter routes, wherever you live

If every return was filed, all income was reported and no tax is owing, filing the late FBARs with a reasonable-cause explanation, or the delinquent information return procedure, may fit better than Streamlined. Neither depends on residence. The IRS removed its Delinquent FBAR Submission Procedures page on 1 July 2026, so late FBARs no longer come with a published no-penalty assurance.

Only then residence

If income was missed or tax is owing, the non-residency test picks the track: no US home and 330 or more full days abroad in the same recent year means the foreign procedure; otherwise the domestic one, with its 5% penalty.

Questions about the screener

What does this screener actually decide?
It narrows seven answers down to the procedure that most likely fits: the Streamlined Foreign Offshore Procedures, the Streamlined Domestic Offshore Procedures, a reasonable-cause late FBAR filing, the Delinquent International Information Return Submission Procedures, the CI Voluntary Disclosure Practice, or no catch-up at all. It also reports the covered years a submission would need today and the domestic 5% penalty estimate.
Is this official, or does it establish eligibility?
Neither. It applies the published IRS eligibility conditions to your answers so you can see the reasoning. Eligibility is decided on your actual residence history, filing history and conduct, and the non-willfulness certification is a signed statement about facts the screener cannot see.
Why does an open IRS examination change the answer?
Because the IRS states that a taxpayer with an open civil examination for any taxable year — whether or not it concerns foreign assets — is not eligible for the Streamlined procedures, and a taxpayer under IRS Criminal Investigation is likewise ineligible. It is a threshold test, so it is applied before anything else.
How are the covered years worked out?
Three tax-return years and six FBAR years, in both cases the most recent ones whose due dates (including properly obtained extensions) have passed at the time of submission. The screener calculates them for today's date, which is why the answer changes during the year.
What is the penalty it estimates?
Only the domestic miscellaneous offshore penalty: 5% of the highest aggregate year-end balance or value of the assets subject to the penalty across the covered periods. The foreign procedure carries no such penalty where all instructions are followed, and neither track reduces tax or interest.

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