The Expat Tax Catch-Up Checklist
For US citizens living abroad who are behind on filing. This is education, not tax advice — confirm your situation with a qualified expat CPA before filing.
1. Figure out how far behind you are
- List every year you have NOT filed a US federal return (Form 1040).
- List every year a foreign bank/financial account total topped $10,000 combined at any point — that triggers FBAR (FinCEN Form 114).
- Note any year you held specified foreign financial assets over the Form 8938 thresholds ($200K end-of-year / $300K any-time for most expats; $50K/$75K if filing from inside the US).
2. Decide if you qualify for the Streamlined Program
- Confirm your failure to file was non-willful — an honest misunderstanding, not deliberate hiding.
- Confirm the IRS has not already contacted you about these years. You must come forward first.
- If you've lived outside the US at least 330 days in one of the last 3 years, you likely qualify for Streamlined Foreign Offshore (SFOP) — penalty-free.
3. Gather your documents
- Last 3 years of US federal tax returns (the ones you'll file under Streamlined).
- Last 6 years of foreign account statements (for the FBARs).
- Foreign income records: pay slips, self-employment income, foreign tax paid.
- Records supporting the Foreign Earned Income Exclusion (FEIE) or Foreign Tax Credit — usually your two biggest tools for zeroing out US tax owed.
4. File the right forms
- 3 years of amended or delinquent federal returns.
- 6 years of FBARs, e-filed through the BSA E-Filing system.
- Form 14653 — the non-willful certification statement, the heart of a Streamlined submission.
- Form 8938 for any year you crossed the FATCA threshold.
5. Don't trip these wires
- Don't "quiet file" old returns one at a time — that can disqualify you from Streamlined.
- Don't assume owing nothing means you don't have to file — filing is required even at $0 owed.
- Don't guess on "willful vs non-willful" — the penalty difference is enormous. When in doubt, get a professional read first.
Want this handled for you?
Greenback Expat Tax Services does Streamlined filings, FBAR, and FATCA/8938 for Americans abroad — CPAs and IRS Enrolled Agents who do this all day.
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Sources: IRS Streamlined Filing Compliance Procedures; FinCEN Form 114 (FBAR); IRS Form 8938 / FATCA. Last reviewed June 2026. Always verify current thresholds and your eligibility with a qualified professional.