The Streamlined Filing Compliance Procedures exist for taxpayers whose failure to file was non-wilful — people who genuinely did not know that moving abroad does not end a U.S. filing obligation.
What non-wilful actually means
It is a statement you sign under penalty of perjury, setting out why the returns were not filed. It is the heart of the submission rather than a formality attached to it, and it is where most of the work goes.
What a submission contains
- Delinquent or amended federal returns for the years in scope
- FBARs covering the corresponding period
- The signed non-wilfulness certification
These procedures are not a permanent fixture. The IRS has closed comparable programmes before, at its own notice and without a long runway. If you are behind, the question is worth asking now rather than later.