Can married couples file one joint Form 14653 for a streamlined submission?

Yes, where the couple is submitting joint returns. Form 14653 accommodates a joint certification, and the IRS treats the statements as made on behalf of both spouses even though the pronoun I is used. Both spouses must sign the two signature lines provided. Where the spouses are filing married filing separately, or only one spouse is a US person, the certification is signed by that individual alone.

Do both spouses need to meet the 330-day non-residency test?

Yes, independently. Form 14653 states that both spouses filing a joint certification must meet the non-residency requirements, and the IRS confirms that for joint return filers both spouses must satisfy the applicable test. There is no averaging between spouses. Where the number of days physically outside the United States differs, the difference must be disclosed on the certification chart or in an attachment rather than smoothed over.

How do we report a joint UK bank account on the FBAR?

Each joint owner who is a US person reports the entire value of the account, not a half share. The account goes in Part III of FinCEN Form 114, with the spouse entered as principal joint owner and the number of other joint owners given excluding the filer. Filing is triggered where all foreign accounts aggregate above 10,000 dollars at any point in the calendar year.

When can one spouse file a single FBAR covering both of us?

Only where three conditions all hold: every account the non-filing spouse must report is jointly owned with the filing spouse, the filing spouse reports those accounts on a timely filed and electronically signed FBAR, and both have completed and signed FinCEN Form 114a. Keep Form 114a with your records rather than sending it. If any condition fails, both spouses file separately and each reports the full account value.

Should we make a section 6013(g) election to include a non-US spouse?

Rarely during a streamlined submission. The election makes both spouses report worldwide income for that year and all later years, generally removes the electing spouse's ability to claim treaty benefits as a UK resident, and cannot be made again once ended. It expands the information in a package where accuracy is critical. Where it is worthwhile, we make it prospectively after the streamlined submission rather than inside it.

What happens if one spouse qualifies for the foreign procedures and the other does not?

The joint foreign submission is unavailable, because both spouses must meet the non-residency test. The usual route is to file the covered years married filing separately so the eligible spouse uses the Streamlined Foreign Offshore Procedures with no offshore penalty. The alternative is a joint domestic streamlined submission carrying a 5 percent miscellaneous offshore penalty on Form 14654, which requires that returns were previously filed for each covered year.

IRS Streamlined Filing for Married Couples: Form 14653

A married couple making an IRS Streamlined Filing under the Foreign Offshore Procedures files one Form 14653, not two, and both spouses sign the same certification. The form is explicit about it: where a certification is a joint certification, the statements are considered made on behalf of both spouses even though the pronoun I is used. What the form will not accept is a single story. Where the spouses have different reasons for the failure to report income, pay tax and file information returns, Form 14653 requires those individual reasons to be stated separately in the statement of facts, and each spouse must independently meet the non-residency requirement.

That is the whole compliance problem for couples compressed into two sentences. One document, two signatures, two sets of facts, two independent eligibility tests. In the streamlined submissions we prepare for London and Home Counties clients, the numbers are rarely what causes trouble. What causes trouble is a certification drafted in one voice for two people whose circumstances diverge, or a couple who assumed that because they file a joint Form 1040 they qualify as a unit. They do not. The IRS tests them one at a time, and if either spouse fails, the joint submission fails with them.

This guide works through the mechanics as they actually apply on a couple's file: one certification or two, whose reasons go where, how the 330-day test is applied to each spouse, what happens when only one spouse is a US person, whether a section 6013(g) election is worth making alongside a streamlined submission, how joint UK accounts land on the FBAR, and what to do when one spouse qualifies and the other does not.

Do spouses file one joint Form 14653 or two separate certifications?

One, where the couple is submitting joint returns. Form 14653, Certification by U.S. Person Residing Outside of the United States for Streamlined Foreign Offshore Procedures, revised March 2025, is built for it. The name field is Name(s) of taxpayer(s), the identification field is TIN(s) of taxpayer(s), and the signature block at the end provides two lines: Signature of taxpayer, and Signature of taxpayer (if joint certification). Both lines must be completed for a joint submission. The current form is at https://www.irs.gov/pub/irs-pdf/f14653.pdf and the procedures it supports are set out at https://www.irs.gov/individuals/international-taxpayers/u-s-taxpayers-residing-outside-the-united-states.

Two separate certifications are appropriate where the spouses are not filing joint returns. If the streamlined years are being filed as married filing separately, or if only one spouse is a US person, the submission belongs to that individual and the certification is signed by that individual alone. There is no mechanism for filing two Forms 14653 covering the same joint Form 1040, and no benefit in trying. The form is designed to hold both narratives.

Two procedural points get missed on couples' files. First, a paid preparer may complete and sign the preparer section, but the form states directly that the signature of the taxpayer or taxpayers is required even if the form is signed by a paid preparer. A preparer signature does not substitute for either spouse's. Second, the IRS requires the original signed certification to be submitted with the package and copies of the same certification to be attached to each tax return in the submission. The whole package goes on paper to Internal Revenue Service, 3651 South I-H 35, Stop 6063 AUSC, Attn: Streamlined Foreign Offshore, Austin, TX 78741. Electronic submissions of the streamlined returns are not accepted.

Why one certification has to carry two separate non-willfulness stories

The statement of facts is where streamlined submissions are won or lost, and it is the part of a couple's file that most often gets underwritten. Form 14653 is unusually direct about what it wants. Any submission that does not contain a narrative statement of facts is treated as incomplete and does not qualify for streamlined penalty relief. The narrative must give specific reasons, favourable and unfavourable, covering personal background, financial background and anything else relevant. It must explain the source of funds in every foreign financial account or asset, and the taxpayer's contacts with each account including withdrawals, deposits and investment or management decisions. Where a professional adviser was relied on, the form asks for that adviser's name, address and telephone number and a summary of the advice given.

Then comes the sentence that governs couples: if married taxpayers submitting a joint certification have different reasons, the individual reasons for each spouse must be provided separately in the statement of facts. In practice, spouses almost always do have different reasons, because they almost always have different histories. One is a US citizen born in the United States who moved to London at twenty-six; the other acquired US citizenship through a parent and has never lived in the country. One opened the Barclays account before the marriage; the other was added to it in 2019. One took advice from a UK accountant who said nothing about US filing; the other took no advice at all.

For each spouse, the narrative on a couple's file has to establish these separately:

How that spouse came to be a US person, and when they first understood that US citizens and green card holders file on worldwide income regardless of where they live.
That spouse's own connection to each account or asset: whose money opened it, who operated it, who made the investment decisions, and whether that spouse ever looked at the statements.
What advice that spouse personally received or did not receive, from whom, when, and what it said. Naming a UK accountant who prepared self assessment returns and never mentioned US filing is a favourable fact, and the form asks for it.
The unfavourable facts belonging to that spouse. A US passport used for travel, a US address on a bank record, a tax organiser question about foreign accounts answered incorrectly. Omitting these is what turns a non-willful narrative into a credibility problem.
Why the failure was negligence, inadvertence, mistake or a good faith misunderstanding of the law, which is how the form defines non-willful conduct.

The failure mode we see most often is a narrative that says we did not know, in the plural, for three pages. Two people who signed the same return did not necessarily fail in the same way, and a certification that flattens them into one voice invites the reviewer to ask which spouse the sentence actually describes.

Do both spouses have to meet the 330-day non-residency test?

Yes, independently, and Form 14653 states it twice. Both spouses filing a joint certification must meet the non-residency requirements. There is no averaging, no spillover and no relief for a spouse who narrowly misses.

For a US citizen or lawful permanent resident, the test is that in any one or more of the most recent three years for which the US return due date, or properly applied for extended due date, has passed, the individual did not have a US abode and was physically outside the United States for at least 330 full days. Note the two limbs. Days outside the country are the easy part; abode is the part that catches people, and the IRS points to Publication 54 at https://www.irs.gov/publications/p54 for what abode means. A spouse who kept a Connecticut house available for their own use, with utilities running and personal effects in place, can be physically outside the United States for a full year and still have a problem.

The form provides a chart in which each spouse answers yes or no for each year, and it adds a specific instruction for couples: if the number of days physically outside the United States differs for each spouse, that must be disclosed on the chart or in an attachment to the certification. Do not average the couple. Disclose the divergence.

Where a spouse is not a US citizen and not a green card holder, the test is different and stricter procedurally. That spouse must attach a computation showing that they did not meet the substantial presence test under IRC section 7701(b)(3). The computation has to disclose days present in the United States for the three years covered by the submission and for the previous two years, because substantial presence looks back across a rolling three-year window. The form is blunt about the consequence: if a complete computation is not attached, the submission is considered incomplete and does not qualify for the Streamlined Foreign Offshore Procedures. That is a whole submission lost on a missing schedule.

How does an IRS Streamlined Filing work when only one spouse is a US person?

This is the common London profile: an American married to a British national, living in the UK, with a joint current account, a joint offset mortgage account, a joint savings account and a stocks and shares ISA in each name. The non-US spouse is not a US taxpayer and has no US filing obligation. The streamlined submission belongs to the US spouse alone.

That means married filing separately for the three streamlined years, a Form 14653 signed by the US spouse only, and a narrative written in one voice because there genuinely is only one taxpayer. It also means a set of consequences that couples routinely underestimate, because married filing separately is not a neutral choice on a cross-border file.

The sharpest of these is Form 8938. For a US person living abroad and filing a joint return, the specified foreign financial asset thresholds are more than 400,000 dollars on the last day of the tax year or more than 600,000 dollars at any point during it. Filing separately, the same person abroad is tested at more than 200,000 dollars and more than 300,000 dollars. Halved. And the valuation rule moves against them at the same time. Where two spouses are both specified individuals and file separate returns, each counts one half of a jointly owned asset. But where the other joint owner is a spouse who is not a specified individual, the Form 8938 instructions at https://www.irs.gov/pub/irs-pdf/i8938.pdf require the US spouse to include the entire value of the jointly owned asset in their own total. A lower threshold applied to a bigger number. A couple with a joint UK account they thought of as half theirs can cross into Form 8938 territory precisely because the other half belongs to a non-US spouse.

Since the streamlined procedures require complete and accurate returns including all required information returns, a missed Form 8938 in year one is not a footnote. It is an incomplete submission.

Should a non-US spouse be brought onto the joint return under section 6013(g)?

A US citizen or resident married to a nonresident alien can elect to treat that spouse as a US resident for income tax purposes. The mechanics are set out by the IRS at https://www.irs.gov/individuals/international-taxpayers/nonresident-alien-spouse. The couple attaches a statement, signed by both spouses, to the joint return for the first year the choice applies. The statement declares that one spouse was neither a US citizen nor a US resident and the other was, that they choose to be treated as US residents for the entire tax year, and gives both spouses' names, addresses and identification numbers. The nonresident spouse needs a Social Security Number or an ITIN. A joint return must be filed for the year the choice is made. A related election applies where a nonresident alien becomes a US resident partway through the year, producing a dual-status year, which is the section 6013(h) situation.

The consequences are permanent in a way that surprises people:

Each spouse must report their entire worldwide income for the year of the choice and for all later years, unless the choice is ended or suspended. The UK spouse's UK salary, UK bank interest, UK dividends and UK fund holdings all enter the US return.
The electing spouse generally cannot claim tax treaty benefits as a resident of a foreign country. For a UK-resident spouse that removes the treaty positions a UK resident would otherwise look to.
The choice ends on revocation, on the death of either spouse, on legal separation, or where records are inadequate. Once ended, neither spouse can make the choice again in any later tax year, even if married to a different person. It is a one-shot election.
The choice is suspended automatically for any later year in which neither spouse is a US citizen or resident, and can revive if that changes.
The UK spouse's foreign financial assets enter the couple's Form 8938 reporting, because a joint return produces one combined Form 8938 covering both spouses' assets.

Is a section 6013(g) election worth making alongside a streamlined submission?

In most of the couples' files we prepare, no, not during the streamlined years. The election and the streamlined submission pull in opposite directions, and the reasons are structural rather than arithmetic.

A streamlined submission is a request for discretionary penalty relief supported by a certification signed under penalties of perjury. Everything in the package has to be right. A 6013(g) election deliberately expands the surface area of that package at the exact moment you want it narrow. The UK spouse's UK employment income becomes US-taxable income requiring credit computations. Their UK-domiciled funds and investment companies become potential passive foreign investment company positions requiring Form 8621 analysis across three years. Their accounts, which were previously nobody's US business, become reportable specified foreign financial assets. Each of those is a new opportunity for an error in a submission where errors are expensive.

The election is also not a one-year experiment. It applies to the year of choice and to all later years until ended, and ending it closes the door permanently for both spouses. A couple making the election to smooth three historical years commits themselves to a filing posture for the rest of the marriage. That decision should be modelled forward across several years, not backwards across three.

There are cases where it earns its place, and they have a recognisable shape. The US spouse has modest income of their own. The UK spouse has substantial UK employment income taxed at UK rates that exceed the equivalent US rates, so foreign tax credits are expected to absorb the US liability with credits to spare. The couple values the joint filing brackets and standard deduction going forward, and neither spouse has UK fund holdings that would generate punitive treatment. Even then, our practice is to make the election prospectively, after the streamlined submission has been filed and accepted in substance, rather than folding it into the same package. Fix the past first with the smallest possible footprint. Optimise the future separately.

How are joint UK accounts reported on the FBAR?

Each joint owner reports the entire value. Not half. The FinCEN electronic filing instructions for FinCEN Form 114 state plainly that each joint owner must report the entire value of the account, and the IRS restates the requirement at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar. A United States person files if the aggregate value of foreign financial accounts exceeds 10,000 dollars at any time during the calendar year. The FBAR is due 15 April with an automatic extension to 15 October which does not have to be requested.

Joint accounts go in Part III of the FBAR. Item 24 asks for the number of joint owners, excluding the filer. Items 25 to 33 capture the principal joint owner, and the instructions specify that where the filer's spouse has an interest in a jointly owned account, the spouse is the principal joint owner. Item 25 asks for that person's taxpayer identification number, which may be an SSN, an EIN or a foreign number, and item 26 takes the joint spousal owner's last name. Where information is genuinely unavailable, the instructions permit those items to be left blank. Records supporting each account must be retained for five years from 15 April of the year following the calendar year reported, or from the filing date if later.

Under the streamlined procedures the couple files FBARs for the most recent six years for which the FBAR due date has passed. Those are filed electronically through the FinCEN BSA E-Filing System at https://bsaefiling.fincen.gov, selecting Other as the reason for late filing and entering Streamlined Filing Compliance Procedures in the explanation box. Note that this is the route for late FBARs generally now that the IRS has withdrawn its separate delinquent FBAR submission page: late FBARs are filed through the BSA E-Filing System with a stated reason, or inside a streamlined submission.

When can one spouse file a single FBAR for both using FinCEN Form 114a?

FinCEN allows a spouse not to file a separate FBAR only where three conditions are all met. All of the financial accounts that the non-filing spouse is required to report are jointly owned with the filing spouse. The filing spouse reports those jointly owned accounts on a timely filed, electronically signed FBAR. And the filers have completed and signed FinCEN Form 114a, Record of Authorization to Electronically File FBARs. Otherwise both spouses must file separate FBARs, and each must report the entire value of the jointly owned accounts.

Form 114a is the enabling document. Where spouses file jointly, both complete Part I in full and sign, and the spouse who will transmit the report completes Part II. The completed form is kept with the filers' records and is not sent to FinCEN. Income tax filing status is irrelevant to the exception: a couple filing married filing separately can still use it, and a couple filing jointly can still fail it.

In practice the exception breaks more often than it holds, because the first condition is absolute. These are the situations we see it fail on:

One spouse retains a sole-name UK current account or an old building society account from before the marriage, even a dormant one, if the couple's aggregate crosses 10,000 dollars.
One spouse has signature authority over an employer's foreign account, a client account or a professional practice account. Signature authority is a reporting trigger in its own right and is not jointly held.
One spouse holds a sole-name UK savings or investment account into which a bonus or a property disposal was paid.
The account is held in one spouse's sole name at the bank even though the couple treats it as shared. FBAR follows the account title and the financial interest, not the household budget.
Form 114a was never completed, or was completed for one year and not the others. It has to exist for each year covered.
The FBAR was not timely filed. In a streamlined submission the historical FBARs are by definition late, so the exception is not available for those years and each spouse who has their own filing obligation files their own FBAR for each of the six years.

That last point deserves emphasis, because it is the one that generates most of the rework. The FinCEN exception is written around a timely filed FBAR. Where a couple is remediating six years of missed FBARs inside a streamlined submission, we file for each spouse who has an independent obligation rather than relying on an exception that was drafted for the compliant case.

What happens when one spouse is eligible and the other is not?

This is the mixed-eligibility couple, and it is the scenario that generic streamlined guides skip entirely. The rule is unambiguous: for joint filers, both spouses must meet the applicable non-residency requirement. If one spouse spent 300 days outside the United States in each of the three years, or maintained a US abode, the couple cannot make a joint Streamlined Foreign Offshore submission. There is no partial relief and no waiver.

There are three practical routes, and choosing between them is the real work on this kind of file.

Separate the spouses for the streamlined years. File married filing separately so the eligible spouse makes a Streamlined Foreign Offshore submission alone, with a single-signature Form 14653, and the ineligible spouse is dealt with on a different track. This preserves the zero-penalty outcome for the spouse who qualifies. The cost is the married filing separately consequences described earlier, including the halved Form 8938 thresholds and the loss of certain credits.
Move the couple to the domestic procedures. The Streamlined Domestic Offshore Procedures at https://www.irs.gov/individuals/international-taxpayers/u-s-taxpayers-residing-in-the-united-states are designed for exactly this: for joint returns, one or both spouses must fail the applicable non-residency requirement. The trade is a Title 26 miscellaneous offshore penalty of 5 percent of the highest aggregate year-end balance and value of the foreign financial assets subject to the penalty across the covered tax return and FBAR periods, certified on Form 14654 rather than Form 14653. Under the foreign procedures no such penalty applies, so the cost of the mixed marriage is measurable.
Check the domestic gateway before relying on route two. The domestic procedures require that the taxpayer previously filed a US tax return, if required, for each of the most recent three years. A spouse who has never filed at all cannot walk into the domestic procedures. If neither streamlined track is open, the remaining options sit outside the streamlined framework entirely and need to be considered with counsel, including where willfulness is genuinely in doubt. The general framework is at https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures.

Illustration, with figures chosen to show the mechanics rather than to describe any client. Assume a couple in Surrey. She is a US citizen who has lived in the UK continuously for eleven years and was outside the United States for more than 330 full days in each of the three relevant years, with no US abode. He is a dual US and UK citizen who took a fourteen-month secondment to his firm's New York office spanning two of those three years and kept an apartment in Manhattan throughout. Their joint accounts are a NatWest current account, a joint savings account and a joint offset mortgage reserve, and she holds a stocks and shares ISA in her sole name. Assume for illustration only an exchange rate of 1.25 dollars to the pound and a highest aggregate year-end asset value of 700,000 pounds, or 875,000 dollars on that assumption. On a joint Streamlined Foreign Offshore submission the couple would face no miscellaneous offshore penalty, but he fails the non-residency test and the joint submission is not available. If they instead file the three years married filing separately, she makes a Streamlined Foreign Offshore submission alone at no offshore penalty, and he is assessed separately. If they take the domestic route jointly instead, a 5 percent penalty applied to the illustrative 875,000 dollar figure is roughly 43,750 dollars. The gap between those two outcomes is the reason the eligibility test is run spouse by spouse before anything else on the file is touched.

What about the non-US spouse's privacy and information disclosure?

This is the conversation nobody puts in writing, and it is often the real reason a couple has stalled for years. A British spouse who has never set foot in the United States as a taxpayer is being asked to have their name, their date of birth, potentially a tax identification number and the balances of accounts they part-own transmitted to a foreign revenue authority. That reluctance is reasonable and it deserves a precise answer rather than reassurance.

The precise answer starts with what is already happening. Where a UK bank account is held jointly and one holder is a US person, that account is a US reportable account and the UK financial institution reports it to HMRC, which exchanges the information with the IRS under the UK and US intergovernmental agreement implemented by the International Tax Compliance Regulations. HMRC's guidance at https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim402140 confirms the attribution rule: each holder of a jointly held account is attributed the entire balance or value of the joint account, as well as the entire amounts paid or credited to it. The account balance the non-US spouse is worried about disclosing has, in most cases, already been reported.

The lawful basis for that reporting is a legal obligation under UK law. The ICO's guidance on the legal obligation basis at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/a-guide-to-lawful-basis/legal-obligation/ explains that Article 6(1)(c) of the UK GDPR permits processing necessary for compliance with a legal obligation to which the controller is subject, and that under Article 6(3) the obligation must be laid down by UK law. The UK regulations implementing the intergovernmental agreement supply that basis. The practical consequence is that a non-US spouse has no realistic route to object to their bank's reporting of a jointly held account, and objecting to the couple's own filing does not stop it.

What remains genuinely within the couple's control is the additional information they volunteer. Here the distinctions matter:

A non-US spouse's name appears on the US spouse's FBAR as principal joint owner for each jointly held account, with a TIN where one is known. That is required and is not optional.
A non-US spouse's sole-name accounts do not go on the US spouse's FBAR at all. There is no financial interest and no signature authority. Including them because they are in the household is a disclosure the couple was never obliged to make.
Without a section 6013(g) election, the non-US spouse's income and assets do not enter the US return. With one, they do, comprehensively and for every later year. This is the single largest privacy consequence of the election and it belongs in the decision, not just the tax modelling.
An ITIN application for a non-US spouse requires certified identity documentation, typically a passport. That is a real intrusion, it is only needed if the couple is making the election or claiming the spouse on a return, and consent should be obtained in writing before anything is submitted.
The Form 14653 statement of facts should describe the US spouse's conduct and the accounts, not the non-US spouse's private finances. Narratives that drift into the UK spouse's affairs disclose more than the certification asks for and add nothing to the non-willfulness case.

Records retention cuts the same way. Form 14653 commits the signatories to retain records relating to income and assets for the covered period until three years from the date of the certification, and where delinquent FBARs were filed, to retain records relating to the foreign financial accounts, including account statements, until six years from that date, producing them to the IRS on request. A non-US spouse who co-signs a joint certification is accepting that obligation over jointly held account records. That is a further reason to keep the couple's structure as narrow as the facts allow.

How are the same joint accounts treated on the UK side?

Differently, and the mismatch is a feature rather than an error. Income from property held jointly by married couples and civil partners is treated as beneficially owned in equal shares and taxed 50/50, under section 836 of the Income Tax Act 2007, regardless of who funded the account. Where the beneficial interests are genuinely unequal, the couple can displace the default by making a declaration on HMRC form 17, described at https://www.gov.uk/government/publications/income-tax-declaration-of-beneficial-interests-in-joint-property-and-income-17, supported by evidence such as a declaration or deed. The election is not a free choice: it must reflect the actual beneficial interests, and it cannot simply be reversed.

So a single joint NatWest account can generate three different numbers in the same year, all of them correct. HMRC taxes half the interest in the hands of each spouse. The FBAR reports the entire balance for each US-person joint owner. And Form 8938, where the other joint owner is not a specified individual, counts the entire value in the US spouse's total. Reconciling those on a workpaper before the returns are drafted saves an amended submission later, and it also pre-empts the question a reviewer will ask when the interest on the return is half of the balance the FBAR reports.

Where the couple also has a UK-side problem, and sometimes they do because the same inattention that produced missed US returns produced unreported UK income, the UK remediation route is HMRC's Worldwide Disclosure Facility at https://www.gov.uk/guidance/worldwide-disclosure-facility-make-a-disclosure. The couple notifies through the Digital Disclosure Service, receives a disclosure reference number, and then has 90 days to compile and submit the disclosure with tax, interest and penalties calculated. It carries no guaranteed immunity from criminal prosecution, which is a material difference from how people imagine these facilities work, and it is a separate exercise from the US streamlined submission with its own timetable.

What we check before a couple's streamlined submission goes out

The eligibility and completeness checks below are run spouse by spouse, before any return is drafted, because every one of them can invalidate the package after it has been mailed.

Each spouse's day count and abode position tested separately for each of the three covered years, with divergent day counts disclosed on the Form 14653 chart or in an attachment rather than averaged.
For a spouse who is not a US citizen or green card holder, a complete substantial presence computation attached covering the three submission years and the two preceding years, without which the submission is treated as incomplete.
Separate non-willfulness narratives for each spouse wherever the reasons differ, including adviser names, addresses, telephone numbers and a summary of the advice.
Both signature lines on Form 14653 completed and dated, with the original signed certification in the package and a copy attached to each return.
Streamlined Foreign Offshore written in red at the top of the first page of each delinquent or amended return and each information return, with the whole package sent on paper to the Austin address.
All required information returns identified for each spouse, including Form 8938 tested at the correct threshold for the actual filing status, and Form 8621 where UK funds are held.
Six years of FBARs filed electronically for each spouse with an independent obligation, using Other as the reason for late filing and entering Streamlined Filing Compliance Procedures in the explanation box.
Form 114a completed and signed for any year where a single FBAR is being filed for both spouses, and retained rather than submitted.
Payment of all tax due and all applicable statutory interest submitted with the package.
A written decision on whether a section 6013(g) election is being made, when, and why, kept on file with the modelling that supports it.

Couples come to this work having spent months hoping the answer is simpler than it is. It is not simpler, but it is finite. Two people, one form, two tests, two stories, and a small number of decisions that have to be made in the right order. Run the eligibility test first, decide the filing status second, decide the 6013(g) question last and preferably not at all during the streamlined years, and the rest of the file follows.