Streamlined Domestic Offshore Procedures (SDOP)
Replace the full FBAR penalty stack with a single 5% offshore penalty. CPA-prepared SDOP submissions for non-willful filers.
Free. No obligation. We respond the same day.
About This Service
How It Works & What to Expect
SDOP is the IRS amnesty path for U.S. residents who missed FBARs, FATCA, or international information returns (Form 5471, 8938, 3520, 8621) due to non-willful conduct. One 5% Title 26 offshore penalty on your highest aggregate year-end balance replaces the full stack: FBAR ($10,000+ per account per year), accuracy (20%), fraud (75%), and per-form information-return penalties ($10,000+ each).
We prepare every piece in a single engagement: three amended Form 1040X returns, six years of FBARs (FinCEN 114), Form 14654 non-willful certification, and any required international forms, all reconciled to one SDOP cover letter with reasonable cause framing. Where SDOP is not the right fit, we use the Delinquent FBAR or Delinquent International Information Return procedures instead.
Who This Is For
- U.S. citizens or green card holders who meet the SDOP residency test
- Anyone with unreported foreign bank, brokerage, retirement, or signature-authority accounts
- Filers who omitted foreign interest, dividends, rental, business, or pension income
- Owners of foreign corporations, partnerships, or PFICs missing Form 5471, 8865, 8858, or 8621
- Recipients of foreign gifts over $100,000 or beneficiaries of foreign trusts missing Form 3520
- Non-willful filers not currently under IRS civil examination
Free. No obligation. Same-day response.
SDOP vs Traditional Catch-Up
Why Filers Choose SDOP Over a Quiet Disclosure
How an SDOP submission compares with the quiet-disclosure approach of filing amended returns or FBARs without entering Streamlined.
Traditional
Quiet Disclosure / Go It Alone
TS CPA Approach
TS CPA SDOP Submission
Penalty Exposure
Filing Scope
Reasonable Cause Framing
IRS Treatment Channel
Time to Resolution
Cost Predictability
Civil Closure of the Years
Penalty Exposure
Quiet Disclosure / Go It Alone
Full FBAR stack of up to $10,000 per account per year for non-willful violations, plus 20% accuracy or 75% civil fraud penalties on unreported foreign income, plus $10,000+ per-form information return penalties.
TS CPA SDOP Submission
Single 5% Title 26 miscellaneous offshore penalty on the highest aggregate year-end balance and unreported foreign asset value, replacing the full stack.
Filing Scope
Quiet Disclosure / Go It Alone
Often only the current year is filed, leaving prior open years exposed and inconsistent across forms.
TS CPA SDOP Submission
Three years of amended Form 1040X returns and six years of delinquent FBARs caught up together, with every required international information return reconciled to a single workbook.
Reasonable Cause Framing
Quiet Disclosure / Go It Alone
Asserted reactively after the IRS issues a penalty notice, with the silence between the missed filing and the response working against you.
TS CPA SDOP Submission
Built proactively into the Form 14654 narrative and SDOP cover letter, framed under the IRS non-willful standard and tied to specific facts in your record.
IRS Treatment Channel
Quiet Disclosure / Go It Alone
Quiet disclosures are a pattern the IRS specifically flags and may elevate to a standard examination of every covered year.
TS CPA SDOP Submission
Submitted through the designated Streamlined channel at IRS Austin, processed under the published Streamlined Filing Compliance Procedures.
Time to Resolution
Quiet Disclosure / Go It Alone
Months or years if an examination opens, with no closing letter and no defined endpoint.
TS CPA SDOP Submission
Most engagements complete in 1 to 2 weeks from kickoff to IRS submission.
Cost Predictability
Quiet Disclosure / Go It Alone
Hourly billing across multiple advisors, with fees that compound quickly if an examination opens.
TS CPA SDOP Submission
Flat-rate engagement quoted up front, with scope fixed in the engagement letter before any work begins.
Civil Closure of the Years
Quiet Disclosure / Go It Alone
Covered years remain audit-eligible under normal statute-of-limitations rules, with no IRS acknowledgment of the catch-up.
TS CPA SDOP Submission
SDOP submissions accepted as filed close the covered years for civil-penalty purposes, replacing the open penalty stack with the single 5% offshore penalty.
What's Covered
SDOP eligibility analysis (residency test, non-willful review, open-exam screen)
Three years of amended Form 1040X returns with previously unreported foreign income
Six years of delinquent FBARs (FinCEN 114) filed via the BSA E-Filing System
Form 14654 non-willful certification with narrative drafted to your specific facts
5% Title 26 offshore penalty calculation tied to source statements
Foreign account inventory: bank, brokerage, retirement, cash-value insurance, signature-authority
Form 8938 (FATCA) on every applicable amended return
Form 8621 PFIC analysis and election (QEF, Mark-to-Market, or Section 1291)
Form 3520 / 3520-A for foreign trusts, gifts over $100,000, and inheritances
Form 5471 / 5472 / 8865 / 8858 catch-up for foreign entity interests
Foreign Tax Credit (Form 1116) on previously unreported foreign income
Cover letter, package assembly, IRS Austin mailing, and post-submission monitoring under Form 2848
Don't see your situation listed?
Tell us about it, we'll helpThe TS CPA Advantage
What You Can Expect
5% Cap Instead of Six-Figure Stacks
One 5% Title 26 offshore penalty replaces the FBAR ($10K/account/year), accuracy (20%), fraud (75%), and per-form information-return penalties. Six-figure exposure becomes a defined, one-time payment.
Civil Closure of the Covered Years
Submissions accepted as filed close the covered years for civil-penalty purposes. The Form 14654 certification is signed under penalties of perjury and tied to your specific facts.
Every Required Form in One Engagement
Amended returns, six FBARs, Form 14654, Form 8938, Form 8621 PFIC elections, Form 3520, and Form 5471 / 5472 / 8865 / 8858, all reconciled to one workbook. No cross-form mismatches that trigger IRS follow-up.
Form 14654 Narrative Drafted to Your Facts
The non-willful certification is the gating document. A weak narrative gets bounced out of Streamlined into a standard examination. We draft it specifically to your record, not a template.
Coordinated With Your Attorney and Foreign Advisor
Tax attorney for the non-willful opinion, foreign accountant for source documents, U.S. CPA for the filings. We run the workflow off one reconciliation file so no advisor duplicates or contradicts.
Flat Fee, Quoted Before Work Begins
Flat fee scoped to your foreign accounts, entities, and income types. Engagement letter, document checklist, and timeline delivered before you sign.
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