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Cross-Border Compliance · IRS Amnesty

Streamlined Foreign Offshore Procedures

For U.S. citizens and green card holders living abroad who have fallen behind on U.S. tax filings. A structured IRS program that restores full compliance without penalties when the failure was non-willful. Principal-led, CPA-prepared, flat fee.

Start With Our Intake Form (305) 306-8481

Biscayne Bay Advisory represents U.S. persons residing anywhere in the world. SFOP engagements are handled remotely through a secure document portal. Our practice is based in Miami with a focus on Americans abroad, foreign nationals with U.S. exposure, and dual-jurisdiction families.

CPA
Licensed & Certified
LL.M.
International Tax Law
Flat Fee
Scoped Before We Start
Form 14653
Narrative Drafted by Principal
Who Qualifies

Eligibility for the Streamlined Foreign Offshore Procedures

SFOP is designed for U.S. persons who live outside the United States, fell behind on their U.S. filings, and did so non-willfully. There are three core requirements, and all three must be met.

Requirement One
U.S. Person Status
You are a U.S. citizen, a lawful permanent resident (green card holder), or in certain cases the estate of a U.S. person. U.S. tax filing obligations apply regardless of where you live.
Requirement Two
Non-Residency Test
In at least one of the three most recent years with a passed filing deadline, you had no U.S. abode and were physically outside the United States for at least 330 full days. Residency for streamlined purposes is not the same as the Foreign Earned Income Exclusion bona fide residence test.
Requirement Three
Non-Willful Conduct
The failure to file returns, report income, pay tax, or submit information returns resulted from negligence, inadvertence, mistake, or a good-faith misunderstanding of the law. This is certified on Form 14653 under penalties of perjury.
Disqualifiers
When SFOP Is No Longer Available
You generally cannot use SFOP if the IRS has already opened a civil examination of any of your returns, if you are under IRS Criminal Investigation, or if the IRS has already assessed a penalty for the relevant years. Acting before the IRS contacts you is the difference between SFOP eligibility and a far more difficult path.
The Submission

What an SFOP Filing Includes

3
Years of Tax Returns
Delinquent or amended Form 1040 returns for the three most recent years with a passed filing deadline, including all required international information returns (Forms 5471, 8938, 8621, 3520, 8865, and others as applicable).
6
Years of FBARs
FinCEN Form 114 filed for each of the six most recent years for which the FBAR due date has passed, submitted electronically through the BSA E-Filing System with the required streamlined explanation.
1
Form 14653 Certification
A signed certification that you meet the non-residency requirement and that your failures were non-willful, supported by a detailed factual narrative. This document is signed under penalties of perjury and carries more weight than any other element of the submission.
The Non-Willful Narrative

Form 14653 Is Not a Template

The Form 14653 non-willfulness statement is the single most important element of an SFOP filing. The IRS reads it carefully. A weak, vague, or overly brief narrative invites scrutiny. A narrative that volunteers too much can open questions the submission was designed to close.

The certification is a legal document signed under penalties of perjury. Getting it right requires professional judgment, not a fill-in-the-blank form.

Our approach is to scope the facts carefully, draft a specific and coherent narrative that explains how and when the obligations were misunderstood, and align the narrative with the return positions in the submission. Every SFOP engagement is handled directly by the principal from intake through filing.

Why Clients Choose Us

A Different Kind of SFOP Practice

Principal-Led, End to End
A licensed CPA with an LL.M. in International Tax Law handles your engagement personally. No handoffs, no offshore data entry, no junior staff drafting your Form 14653.
Cross-Border Fluency
SFOP work almost always touches foreign pensions, PFICs, CFCs, foreign trusts, and treaty positions. We catch the issues that volume filers miss and plan for them properly.
Flat Fee, Scoped Upfront
We review your facts, quote the engagement in writing, and stand behind that number. No hourly billing, no creeping scope, no surprise invoices.
Narrative as a Deliverable
Your Form 14653 narrative is drafted with the same rigor as a legal brief. We scope the facts with you, draft, revise, and only submit when the story is coherent and defensible.
Secure, Remote Engagement
Every step runs through a secure document portal. We work with clients in Europe, Asia, the Middle East, and Latin America without ever requiring an in-person meeting.
Post-Submission Continuity
After your SFOP submission, you are expected to remain compliant going forward. We stay on as your year-over-year preparer so compliance does not slip again.
Not Sure if You Qualify for SFOP vs. SDOP?
SFOP is for U.S. persons residing outside the United States and carries no miscellaneous offshore penalty. SDOP is for U.S. residents and carries a 5% penalty on the highest aggregate balance of unreported foreign assets. The residency distinction for streamlined purposes is technical and not always obvious, particularly for dual nationals and recent returnees. A short intake conversation will clarify which path applies.
Request a Confidential Consultation
How It Works

From First Conversation to Filed Submission

1
Confidential Intake
We review your facts, residency history, foreign accounts and assets, and confirm SFOP eligibility before engagement.
2
Scoped Engagement
Flat-fee engagement letter with a clear scope and timeline. Document collection begins through our secure portal.
3
Preparation & Narrative
Three years of returns, six years of FBARs, and a full Form 14653 narrative drafted, reviewed, and refined with you.
4
Submission & Follow-Up
Paper submission to the designated IRS service center in Austin, FBARs filed electronically, and post-submission monitoring.

Already compliant and looking for year-over-year expat tax preparation? Many SFOP clients transition into our ongoing cross-border tax preparation engagements.

Explore Tax Preparation →
Common Questions

SFOP Questions & Answers

Do I have to file U.S. taxes if I live abroad?
Yes. U.S. citizens and green card holders are required to file U.S. tax returns and report worldwide income regardless of where they live. This obligation does not end when you move overseas. Many Americans abroad also have separate reporting obligations for foreign bank accounts (FBAR), foreign financial assets (Form 8938), foreign businesses (Form 5471), and foreign trusts or gifts (Form 3520).
Who qualifies for the Streamlined Foreign Offshore Procedures?
You must be a U.S. citizen or green card holder who meets the non-residency requirement (physically outside the U.S. for at least 330 full days in at least one of the most recent three years with a passed return due date, and no U.S. abode for that year), and your failure to file must have resulted from non-willful conduct. You must not be under IRS audit or criminal investigation, and prior penalties for the relevant years may disqualify you.
How many years of tax returns do I need to file?
Three years of delinquent or amended U.S. tax returns and six years of FBARs. You do not need to go back further than this, even if you have been non-compliant for longer. The lookback periods are fixed by the program.
What is non-willful conduct?
The IRS defines non-willful conduct as conduct due to negligence, inadvertence, or mistake, or conduct that results from a good-faith misunderstanding of the requirements of the law. The non-willful certification is a legal document signed under penalties of perjury. Drafting a specific, honest, and coherent narrative is one of the most important parts of an SFOP submission.
What penalties apply under SFOP?
None, for taxpayers who qualify. SFOP waives failure-to-file, failure-to-pay, accuracy-related, information return (including Form 5471 and Form 8938), and FBAR penalties. You pay any back taxes owed plus interest. Many clients owe little or nothing once the Foreign Earned Income Exclusion and Foreign Tax Credit are applied.
How much will I owe in back taxes?
It depends on your income, the countries where you earned it, and the exclusions and credits that apply. For many expats who worked abroad, the Foreign Earned Income Exclusion (up to the annual limit) or the Foreign Tax Credit eliminates U.S. tax entirely, leaving only interest on any residual balance. For higher-income filers, those with investment income, or PFIC holders, the tax calculation is more involved. We quantify this early in the engagement so there are no surprises.
Is SFOP still available in 2026?
Yes. As of 2026, the IRS lists the Streamlined Filing Compliance Procedures as an active compliance option. The IRS has discussed ending the program in the past and can modify or close it at any time, so eligible taxpayers are generally well advised not to delay.
What is the difference between SFOP and SDOP?
SFOP applies to U.S. persons residing outside the United States and carries no miscellaneous offshore penalty. It also permits filing original returns, not only amendments. SDOP applies to U.S. residents, carries a 5% miscellaneous offshore penalty on the highest aggregate balance of unreported foreign assets, and only permits amending previously filed returns.
Can the IRS find out about my foreign accounts?
Generally, yes. Under FATCA, foreign financial institutions report U.S. account holders directly to the IRS. The United States also has information exchange agreements with most major jurisdictions. If the IRS contacts you about unreported foreign accounts before you file under SFOP, you are likely no longer eligible for the program. Timing matters.
How is BBA different from a volume expat tax service?
Biscayne Bay Advisory is a principal-led boutique practice. A licensed CPA with an LL.M. in International Tax Law prepares and reviews every engagement personally. We scope each SFOP filing individually, draft the Form 14653 narrative with the care it requires, and stand behind a flat fee quoted in writing before work begins.

Ready to Come Back Into Compliance?

Start with our online intake form. It takes about five minutes and we will follow up within one to two business days to confirm your eligibility and scope the engagement.

Start With Intake Form (305) 306-8481