Do I file my FBARs with my streamlined package?

No, and doing so is the most common fatal packaging error. FinCEN Form 114 is a Bank Secrecy Act report and the only place it can be filed is FinCEN's BSA E-Filing System. The IRS states on its own FBAR page that you do not file the FBAR with your federal tax return. E-file the six years first, select Other as the reason for late filing with the streamlined explanation, save each confirmation, and only then sign Form 14653 and mail the paper package.

Can I e-file a streamlined submission instead of posting it?

No. The IRS instruction is that the documents must be sent in paper form and that electronic submissions will not be accepted. This overrides the ordinary ability to e-file a Form 1040 or Form 1040-X. A streamlined return that is e-filed has been filed, but not under the streamlined procedures, because the signed certification and the red-ink identification never reach the campus with it.

What exactly do I write in red ink, and where?

Write Streamlined Foreign Offshore in red at the top of page one of each of the three delinquent or amended returns and at the top of each information return in the package, and repeat it on the certification. Apply it by hand in red ink to the printed pages that are actually being mailed. A monochrome print run defeats software-generated red text, so check the physical pages before sealing the envelope.

Does the IRS confirm receipt or send an acceptance letter?

No. The IRS states that it does not acknowledge receipt of streamlined returns and that the process does not culminate in a closing agreement. There is no acceptance letter and no case number. Your tracked delivery proof, your BSA E-Filing confirmations and your payment receipts are your only record, and account transcripts showing the returns and payments posted are the practical substitute for confirmation. Silence with no notices is the normal successful outcome.

How do I pay the tax and interest if I bank in the UK and have no US bank account?

EFTPS requires a US bank account, so the usual route is the IRS Foreign electronic payments process: complete the Same-Day Taxpayer Payment Worksheet with the correct five-digit tax type code and tax period and take it to your UK bank for an international wire. Your bank must have a banking relationship with a US bank, payment must be in US dollars, and the IRS warns the method can be costly. Send one payment per year, each carrying your taxpayer identification number, and compute interest forward to a realistic posting date.

IRS Streamlined Foreign Offshore Procedure: The Pack

Q: Where do I mail my IRS Streamlined Foreign Offshore Procedure submission?

The IRS publishes the address on its streamlined foreign offshore page as Internal Revenue Service, 3651 South I-H 35, Stop 6063 AUSC, Attn: Streamlined Foreign Offshore, Austin, TX 78741. Confirm it on the IRS Streamlined Filing Compliance Procedures pages on the day you print the label, because IRS campus addresses and attention lines do change and the address the IRS gives for correcting an already-filed package uses a different attention line.

A complete IRS Streamlined Foreign Offshore Procedure submission has exactly four components: three years of delinquent or amended US income tax returns for the most recent years for which the return due date has passed, six years of FBARs filed separately and electronically through the FinCEN BSA E-Filing System, a Form 14653 certification signed under penalties of perjury, and full payment of the tax and statutory interest due. Three of those four go in one paper envelope to a single dedicated address in Austin, Texas. The FBARs do not. That distinction is the single most common fatal packaging error we see, and it is the reason otherwise well-prepared submissions arrive incomplete.

This article is about the envelope itself. It assumes you have already satisfied yourself that you meet the non-residency requirement and that your failures were non-willful, and it does not revisit the abode test, the 330-day test or the drafting of the certification narrative. What follows is the assembly and despatch discipline: what goes in, what never goes in, what must be written in red ink and where, how a filer banking in London actually pays the Internal Revenue Service, and what to retain given that the IRS will never write back to confirm that anything arrived.

What exactly goes into an IRS Streamlined Foreign Offshore Procedure submission?

The IRS sets out the required components on its Streamlined Filing Compliance Procedures pages, specifically the page for US taxpayers residing outside the United States. A submission is complete only when all four elements below have been delivered by their correct route. Partial delivery is not partial credit - a package missing a required element is exposed to being treated as an incomplete submission, which puts the penalty relief the programme offers at risk.

Three years of returns. For each of the most recent three years for which the US return due date (including any properly filed extension) has passed, a delinquent Form 1040 if none was filed, or an amended return if an incomplete or inaccurate one was filed. Every required schedule and every required international information return must be attached to the year it belongs to.
Six years of FBARs. FinCEN Form 114 for each of the most recent six years for which the FBAR due date has passed, filed electronically through the FinCEN BSA E-Filing System. Not three years. Not the same six years as the returns. Six.
Form 14653. The Certification by U.S. Person Residing Outside of the United States, completed and signed under penalties of perjury. Use the current revision published on IRS.gov at the time you file - the form has been revised more than once and a superseded version invites correspondence.
Payment in full. All tax due as shown on the three returns, plus all applicable statutory interest. The IRS instruction is explicit that your taxpayer identification number must be included on the payment so it can be matched to your account.

Note what is not on that list. There is no application form, no user fee, no pre-clearance step and no waiting period. Unlike a voluntary disclosure, there is nothing to be admitted into. You assemble, you send, and the returns enter normal processing. There is also no miscellaneous offshore penalty for a foreign offshore filer, which is the whole commercial point of qualifying under the foreign rather than the domestic track.

Why do the FBARs not go in the paper package?

The FBAR is not an IRS form. FinCEN Form 114 is a Bank Secrecy Act report owed to the Financial Crimes Enforcement Network, and the only place it can be filed is the BSA E-Filing System. The IRS states the point plainly on its own FBAR page: you do not file the FBAR with your federal tax return. Printing six years of Form 114 and posting them to Austin with the returns does not file them. It creates six unfiled FBARs sitting in a paper file in Texas, and it means the certification you signed under penalties of perjury - which asserts that the required FBARs have been filed - is not accurate as at the date you signed it.

The correct sequence is to e-file the six FBARs first, capture the confirmation for each year, and then complete and sign Form 14653 and mail the paper package. Filing the FBARs first also forces the account inventory to be finalised before the returns are signed off, which is exactly the order you want, because the FBAR maximum balances drive the interest and dividend reporting on the returns.

File each of the six years as a separate FinCEN Form 114 submission through the BSA E-Filing System. There is no combined multi-year filing.
Where the system asks for the reason the FBAR is late, the IRS instruction for streamlined filers is to select Other and to enter the explanation that the FBARs are being filed under the Streamlined Filing Compliance Procedures.
Report the maximum value of each reportable account during that calendar year, converted to US dollars. Include jointly held accounts, accounts held through a UK entity where a financial interest exists, and accounts over which you hold only signature authority.
Save the confirmation and the tracking identifier for every single year. These identifiers are the only evidence that the FBAR half of your submission happened at all.
Do not put copies of the filed FBARs in the paper envelope in the belief that this is required. The IRS instructions for the streamlined foreign offshore procedures do not call for FBAR copies in the paper package; the electronic filing is the filing.

What is the red ink rule and where exactly does the red ink go?

The IRS requires the words Streamlined Foreign Offshore to appear, written in red, at the top of the first page of each delinquent or amended tax return and at the top of each information return included in the submission. This is not decoration. The Austin campus routes streamlined work by that marking. A return that arrives without it is liable to be worked as an ordinary late or amended filing, which means the automatic penalty routines that the streamlined procedures are designed to switch off can run against it.

In practice, the marking is applied by hand in red ink after printing, on the physical copy that is mailed, and it is repeated on the certification itself so that the whole package is unambiguously identified. If you are filing amended returns rather than original delinquent ones, the same discipline applies to the amended forms. The rule that trips people is scope: it is not one marking on the top return in the stack, it is a marking on the top of page one of every return and every information return in the package.

Page 1 of each of the three Forms 1040 or 1040-X - red ink, top of the page, above the printed heading area, legible and not obscuring any entry.
Page 1 of each international information return in the package, treated individually rather than as an appendix to the return it accompanies.
The top of Form 14653 itself, so the certification cannot be separated from the streamlined identity of the package.
Use an actual red pen on the printed pages. Printing the words in red from the software is not what the instruction contemplates and a monochrome print run will silently defeat it - a routine failure worth checking before the envelope is sealed.

Where do I mail my streamlined submission, and can I e-file it?

You cannot e-file a streamlined package. The IRS is explicit that the documents must be sent in paper form and that electronic submissions will not be accepted. That instruction overrides the ordinary rule that a current-year Form 1040 or a Form 1040-X can be transmitted electronically. A streamlined return that is e-filed has been filed, but it has not been filed under the streamlined procedures, because the certification and the red-ink identification never reached the campus with it.

As published by the IRS on its streamlined foreign offshore page, the submission address is Internal Revenue Service, 3651 South I-H 35, Stop 6063 AUSC, Attn: Streamlined Foreign Offshore, Austin, TX 78741. Addresses do change, and the IRS moves work between campuses. Confirm the address on the IRS Streamlined Filing Compliance Procedures pages on the day you print the label rather than relying on any secondary source, including this one. Note also that the address the IRS gives for correcting an already-submitted package differs in its attention line, so do not reuse an old label for a later correction.

Send the whole package in one envelope or courier pouch. Splitting years across separate consignments is how a submission ends up half-processed: one year worked, two years unassociated, and a certification sitting on a file with no returns attached to it. Use a tracked international courier or a tracked postal service that produces a signature on delivery. From the UK, allow for customs documentation on the consignment and do not use a service that requires the recipient to collect.

What does complete and accurate mean for the three returns?

Complete and accurate means the return you would have filed had you filed correctly at the time - all worldwide income, all elections properly made, all foreign tax credits or exclusions correctly claimed and substantiated, and every international information return that the facts require. The IRS reserves the right to select streamlined returns for audit under its normal selection processes and to subject them to verification procedures against third-party information, and under FATCA it already holds account-level data reported by UK financial institutions. A package that reports fewer accounts than the IRS can already see is the worst of all outcomes.

For our client base the information return schedule is usually the substance of the work, not the Form 1040 itself. The forms most often required in a UK context, and most often missed, include the following.

Form 8938, Statement of Specified Foreign Financial Assets, where the reporting thresholds for a taxpayer living abroad are met. This is an IRS form and it does belong in the paper package, unlike the FBAR.
Form 5471 for an interest in a UK limited company - the single most expensive form to omit, and the one that most often turns a straightforward catch-up into a substantial exercise.
Form 8865 for an interest in a UK partnership or LLP, and Form 8858 where a foreign disregarded entity or a foreign branch is in the picture.
Form 8621 for holdings in UK-domiciled funds, OEICs and closed-ended investment companies that are passive foreign investment companies, including holdings inside a general investment account or an ISA.
Form 926 for transfers of property to a foreign corporation, which is easily overlooked when a UK company was capitalised during one of the covered years.
Schedule B Part III, where the foreign account questions must be answered consistently with the FBARs you have just e-filed.

One consistency check is worth more than any other. The set of accounts on the six FBARs, the set of assets on Form 8938, the Schedule B answers and the income actually reported on each return must tell the same story. Three separate preparers working three separate years will produce three separate stories, and a reviewer comparing the years will see it immediately.

Do I need a taxpayer identification number before I file?

Yes. The IRS states that all returns submitted under the streamlined procedures must have a valid taxpayer identification number. For a US citizen that is a Social Security Number, and if you have never been issued one, obtaining it is a prerequisite that needs to start early because it is not a same-week process from outside the United States. Where an individual in the submission is not eligible for an SSN - most commonly a non-US spouse being included on a joint return - the IRS permits the submission to proceed accompanied by a complete ITIN application, submitted together with the required returns rather than in advance of them. In that case the returns travel with the Form W-7 and its supporting identity documentation, and the ITIN is issued as part of processing. Do not mail the streamlined package to Austin and the W-7 separately to the ITIN unit; that separation is how a package stalls.

How do I pay the tax and interest from the UK?

The IRS requires payment of all tax shown on the three returns plus all applicable statutory interest, and it does not compute the interest for you before you file. Interest runs from the original due date of each year's return until the date the money is actually received, at underpayment rates the IRS resets quarterly. Because those rates change, no article can give you a figure - the computation has to be done for your specific years and carried forward to a realistic posting date. Build in a margin. A small overpayment produces a refund or a credit; a shortfall produces a balance-due notice for that year some months later, which is an administrative nuisance rather than a failure of the submission, but it undermines the clean file you are trying to create.

The practical obstacle for a UK-resident filer is that EFTPS requires a US bank account. If you do not have one, the IRS Foreign electronic payments route exists precisely for this situation: you complete the Same-Day Taxpayer Payment Worksheet with the correct five-digit tax type code and the correct tax period, and take it to your bank to request an international wire. Your UK bank must have a banking relationship with a US bank for this to work, which the large clearers do and some smaller institutions do not. Payment must be remitted in US dollars, and the IRS itself warns that this route can be costly in bank charges.

Make a separate payment for each tax year, each identified with its own tax period. One lump sum covering three years will be applied by the IRS in its own order and is far harder to reconcile later.
Put the taxpayer identification number on every payment, as the IRS instruction requires, whether the payment is a wire or a cheque.
If you do hold a US bank account, IRS Direct Pay is the simpler route and produces an immediate confirmation number per payment - capture it for each year.
Card payments through the IRS-authorised processors work from a UK card but carry a processing fee, and the fee on a six-figure balance is material.
Time the payment against the despatch of the envelope. Paying two weeks before the returns arrive is fine and stops interest accruing; paying two months after the returns arrive means the returns post as unpaid balances first.

A worked example: assembling the pack for a London filer

Take Marcus Ellery, a fictional but entirely typical client: a US citizen, resident in London for eleven years, a managing director at an investment bank, married to a UK national. He has a joint Coutts current account, a HSBC savings account, a stocks and shares ISA holding UK-domiciled funds, a brokerage account holding UK closed-ended investment companies, and a 12 per cent shareholding in a private UK advisory company he co-founded with two colleagues. He last filed a US return before he moved. His aggregate account balances have been well over the USD 10,000 FBAR threshold every year.

The build ran in this order. First, the account inventory and six years of maximum balances, converted to US dollars year by year. Then the six FinCEN Form 114 filings through the BSA E-Filing System, each marked as late for the streamlined reason, with six confirmations captured to the file. Then the three returns for the most recent three years for which the due date had passed, each carrying Form 8938, a Form 8621 for the funds and closed-ended investment companies including those inside the ISA, and a Form 5471 for the UK advisory company. Only then the certification, signed once the return figures were final, because signing a certification that references filings not yet made is signing something untrue.

The balances due arose almost entirely from the PFIC holdings, not from employment income, which UK tax paid had largely covered. Interest was computed to a date three weeks forward and three separate wires were sent from his UK bank, one per tax year, each with its own tax type code and tax period, each carrying his Social Security Number. The paper package - three returns with red-ink markings on page one of each return and each information return, the signed Form 14653 with copies of it attached to every return and information return, and copies of the payment confirmations for the file - went to Austin by tracked courier in a single consignment. His ISA, incidentally, received no US shelter at all; it is a taxable account for US purposes and the funds inside it are the reason he owed money.

Does the IRS acknowledge receipt of a streamlined filing?

No. The IRS states on its Streamlined Filing Compliance Procedures pages that it does not acknowledge receipt of streamlined returns and that the process will not culminate in the signing of a closing agreement. There is no acceptance letter, no case number, no confirmation that the certification was accepted and no notification that the file has been closed. For clients accustomed to HMRC correspondence and reference numbers, this is genuinely disorienting, and it is the single most common source of anxiety in the months after filing.

What you get instead is indirect. Each return posts to your IRS account and becomes visible on the account transcript for that year, typically some months after receipt. Payments post against the year they were applied to. If something is wrong you receive a notice about that specific thing - a balance due, an adjustment, a request for a missing form. Silence is not formal acceptance, but a full set of posted returns with the payments correctly applied and no notices is the practical equivalent, and monitoring transcripts is how a competent preparer confirms the submission landed rather than waiting for a letter that will never come.

The despatch evidence file: your only proof the submission exists

Because the IRS will never confirm receipt, the burden of proving that you filed, what you filed and when you filed it rests entirely with you, potentially years later and potentially in front of an examiner who cannot locate the package. Treat despatch as an evidence exercise. Everything below should exist in a single retained file, complete on the day the envelope leaves, and it should be preserved for at least as long as the years remain open - separately noting that the IRS requires FBAR supporting records to be kept for five years from the FBAR due date.

A complete scanned copy of the exact paper package as mailed - every page, in order, including the red-ink markings visible in colour on each page one.
The courier airway bill or postal tracking number, plus the delivery confirmation and signature, downloaded and saved rather than left on a carrier website that purges records.
The BSA E-Filing confirmation and tracking identifier for each of the six FBAR years, saved individually.
Payment confirmations - wire receipts, Direct Pay confirmation numbers or processor receipts - one per year, showing the amount, the tax period and the date.
The interest computation worksheet showing how the figure paid for each year was derived and to what date.
A dated file note recording who signed what, when, and the date of despatch. If an ITIN application travelled with the package, keep a copy of the Form W-7 and a record of which identity documents were sent.

The assembly checklist and the QA pass before mailing

Run this as a formal pass, ideally by someone who did not prepare the returns, on the printed package rather than on screen. Almost every defect that causes a streamlined submission to go wrong is visible on the paper in front of you.

Years: are the three return years the correct three - the most recent for which the due date has passed - and are the six FBAR years the correct six? Confirm against the calendar, not against last year's file.
FBARs: six confirmations in hand, one per year, all showing the streamlined late-filing reason, all filed before the certification was signed.
Red ink: page one of every return and every information return, plus the certification, marked by hand in red. Fan the package and check each one.
Certification: current revision, correctly identifying the covered years, signed and dated under penalties of perjury by each filer, with a copy attached to every return and every information return.
Consistency: FBAR accounts reconcile to Form 8938, to the Schedule B answers and to the income reported. Currency translation applied on a consistent basis across all years.
Information returns: every Form 5471, 8865, 8858, 8621 and 926 the facts require, attached to the correct year rather than to the top of the stack.
Payment: computed to a realistic date, one payment per year, taxpayer identification number on each, confirmations captured.
Identification: valid SSN or ITIN for every person on every return, or a complete Form W-7 travelling inside the same envelope.
Route: paper, one consignment, tracked, to the address confirmed on IRS.gov that day - and not one page of it e-filed.
Record: the full scan, the tracking, the confirmations and the file note saved before the package leaves your hands.

What about the Delinquent FBAR Submission Procedures?

This matters for anyone considering whether a lighter-touch route exists. The IRS removed its Delinquent FBAR Submission Procedures page from IRS.gov on or about 1 July 2026, without a formal announcement. That route should not be presented or relied upon as a currently published alternative. Removing a published page does not change the underlying law, and late FBARs can still be filed with a reason for lateness through the BSA E-Filing System, but the specific published assurance of penalty relief that filers previously relied on is no longer there to point at. For anyone who has both unreported income and unfiled FBARs, the delinquent FBAR route was never available in any event, and the streamlined foreign offshore procedures remain the mainstream route - which is precisely why getting the submission pack right has become more important, not less.

The packaging errors that actually cause damage

Mailing the FBARs to Austin with the returns instead of e-filing them through FinCEN. The submission is incomplete and the certification is inaccurate as signed.
E-filing the returns because the software offered to. The returns are filed, but not under the streamlined procedures.
Missing an international information return, most often a Form 5471 or a Form 8621. This is the defect most likely to let the IRS treat the submission as incomplete.
No red ink, or red ink on only the first return in the stack.
Filing three years of FBARs to match the three years of returns.
Sending the returns without the payment, or with a payment that covers tax but not interest and cannot be matched to a year.
Splitting the package across multiple envelopes or multiple dates.
Signing the certification before the FBARs and the returns are actually final.

None of these are conceptual failures. They are document control failures, and they happen to sophisticated filers with good advisers because the assembly step is treated as clerical after the analytical work is done. It is not clerical. The package is the submission - it is the only thing the IRS ever sees, it arrives once, it is never acknowledged, and there is no dialogue in which to correct a first impression. Build it as a controlled document set, check it as one, and retain it as one.