Streamlined Filing Compliance Procedures (SDOP & SFOP)

Both are tracks of the IRS Streamlined Filing Compliance Procedures for non-willful filers. SDOP is for U.S. residents and carries a 5% offshore penalty; SFOP is for taxpayers who lived abroad and carries no penalty, only tax and interest. Both file three years of returns, six years of FBARs, and a non-willful certification (Form 14654 for SDOP, Form 14653 for SFOP). SFOP also allows original delinquent returns.

A quiet disclosure means filing amended or delinquent returns and FBARs on your own without entering an IRS program, which leaves the full penalty stack in place, up to $10,000 per account per year plus the 20% accuracy, 75% fraud, and $10,000+ per-form information-return penalties, and the IRS flags the pattern and can elevate it to a full examination. The Streamlined Filing Compliance Procedures are the official IRS track for non-willful filers: the Streamlined Domestic Offshore Procedures (SDOP) replace that stack with one 5% offshore penalty for U.S. residents, and the Streamlined Foreign Offshore Procedures (SFOP) carry no penalty for taxpayers who lived abroad, both submitted through the designated Streamlined channel with a non-willful certification on Form 14654 or 14653.

You meet it if, in one of the three most recent years, you had no U.S. abode and were physically outside the United States at least 330 full days (they need not be consecutive but must fall in one tax year). A U.S. vacation home does not by itself create a U.S. abode, and joint filers must each qualify. A non-citizen who is not a green card holder qualifies for any year they did not meet the substantial presence test.

The SDOP 5% applies to the highest aggregate year-end balance of the foreign assets subject to the penalty during the six-year FBAR and three-year tax window (assets unreported on an FBAR or Form 8938, or that generated unreported income). SFOP carries no penalty; filers pay only tax and interest, often cut to near zero by the Foreign Tax Credit and FEIE.

Yes. SFOP permits original delinquent returns for the three covered years, so expats, accidental Americans, and immigrants who returned home and never filed can come into compliance, provided the conduct was non-willful and they meet the non-residency test. SDOP requires amended Form 1040X because residents have already filed.

Conduct due to negligence, inadvertence, mistake, or a good-faith misunderstanding of the law, required for both tracks. Common patterns are accidental Americans, long-term expats, and taxpayers who paid local tax abroad but missed the FBAR or Form 8938. Willful conduct disqualifies you and routes to the IRS Voluntary Disclosure Practice. Your Form 14654 or 14653 narrative is signed under penalties of perjury.

Most SDOP and SFOP engagements reach IRS submission in 1 to 2 weeks. Streamlined submissions are not automatically audited and receive no closing letter; they are processed, but the IRS keeps the right to examine any covered year. A documented, reconciled submission is the best protection.

No. Neither track is available once the IRS opens a civil examination of any covered year, and both require a valid SSN or ITIN. A CP2000 underreporter notice does not disqualify you, but a formal examination notice does. Where Streamlined does not fit, we work the DIIRSP procedures, and for a late FBAR standing alone we confirm the current route before filing, because the IRS removed its Delinquent FBAR Submission Procedures page on July 1, 2026.

A flat fee scoped to your accounts, entities, and income types, quoted before you sign. The 5% SDOP penalty is paid to the IRS, not to TS CPA, and SFOP carries no IRS penalty, often making the foreign track very low cost. Cases with controlled foreign corporations (CFCs, Form 5471), PFICs (Form 8621), or foreign trusts and inheritances (Form 3520) are quoted separately.