Streamlined Foreign Offshore Procedures UK Guide |

Introduction

If you are a US citizen or Green Card holder living in the UK with missed US tax filings piling up alongside undeclared UK bank accounts, the Streamlined Foreign Offshore Procedures UK route is the IRS amnesty framework that brings you into full compliance with zero penalty exposure for qualifying non-willful taxpayers. By the end of this guide, you will understand exactly what SFOP is, the precise eligibility criteria covering the 330-day foreign residency test and the non-willful conduct standard, the scope covering three years of late Form 1040 returns plus six years of FBARs, the application process from initial diagnostic through final IRS submission, the Form 14653 non-willfulness certification drafting, the post-submission monitoring, and the 2026 enforcement context that makes prompt action time-sensitive. This guide is written for US citizens in the UK with missed US filings, US-UK dual citizens, US Green Card holders, accidental Americans, and any UK expats considering the SFOP route. For our full SFOP service, see our Streamlined Filing Compliance Procedures.

What Are the Streamlined Foreign Offshore Procedures in the UK?

The Streamlined Foreign Offshore Procedures UK framework refers to the SFOP arm of the IRS Streamlined Filing Compliance Procedures, which applies to US citizens and Green Card holders living in the United Kingdom. The Internal Revenue Service created the broader streamlined framework in 2012. It substantially expanded it in 2014 to provide a structured amnesty route for non-willful taxpayers with missed US tax filings and undisclosed offshore accounts.

The framework includes two procedures. SFOP applies to taxpayers meeting the foreign residency test, defined as physical presence outside the US for at least 330 full days in one of the three most recent tax years for which the US tax return due date (including extensions) has passed. The Streamlined Domestic Offshore Procedures (SDOP) apply to U.S. resident taxpayers with undisclosed offshore accounts. For UK-based Americans, SFOP applies in almost all cases because continuous UK residence easily clears the 330-day threshold.

The scope under SFOP covers three years of late Form 1040 federal income tax returns with all relevant schedules and information returns, six years of FinCEN Form 114 Foreign Bank Account Report filings through the BSA E-Filing System, calculation and payment of any underlying US tax owed plus statutory interest under IRC Section 6601, and the Form 14653 non-willfulness certification signed under penalty of perjury. For submissions made during 2026, the three Form 1040 years are typically 2022, 2023, and 2024, and the six FBAR years are typically 2019 through 2024.

The penalty waiver under SFOP is the central benefit. SFOP carries zero FBAR penalty under 31 USC 5321, zero failure-to-file penalty under IRC Section 6651, zero failure-to-pay penalty, zero Form 8938 FATCA penalty under IRC Section 6038D, zero Form 8621 PFIC reporting failure penalty under IRC Section 1298(f), and zero miscellaneous offshore penalty. The taxpayer pays only the underlying US tax owed plus statutory interest from the original due date. The IRS streamlined filing page sits at https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures.

Why Streamlined Foreign Offshore Procedures UK Matters More Than Ever in 2026

The 2026 context has produced three specific drivers that make the Streamlined Foreign Offshore Procedures UK route materially more time-sensitive than in earlier years.

First, FATCA enforcement reached full operational maturity in 2024 and 2025. UK banks now systematically identify US-citizen account holders using US place-of-birth indicators in passport scans, address records, and citizenship-status questions during account opening. UK investment platforms apply enhanced identification procedures to all new account openings. The IRS now operates automated cross-reference workflows that compare FATCA data against filed Form 8938 and FBAR records, generating enforcement contact triggers for identified non-compliance. The narrowed window for unprompted disclosure makes prompt SFOP submission time-sensitive because the route is only available before IRS contact.

Second, the IRS Large Business and International Division review of SFOP submissions has been refined through 2024 and 2025 with more sophisticated screening for indicators of willful conduct or technical errors. Generic Form 14653 narratives are subject to scrutiny under the refined review. Strong narratives that address the specific factual circumstances against the IRS willfulness framework, as articulated in Bedrosian v United States and Bittner v United States, yield more favorable outcomes.

Third, the FA 2025 long-term residence framework, which came into force on 6 April 2025, brings UK residents into the UK Inheritance Tax worldwide net at the 10 of 20 years' residence trigger. Clean US compliance through the SFOP route becomes a prerequisite for cross-border estate planning that protects against the new UK IHT exposure under the residence-based framework. For a wider context, see our FBAR Penalty Defense service.

The Three Core Pillars of Streamlined Foreign Offshore Procedures UK Eligibility

The 330-Day Foreign Residency Test

The first pillar of Streamlined Foreign Offshore Procedures UK eligibility is the foreign residency test under the SFOP framework. The test requires that in one of the three most recent tax years for which the US tax return due date (including extensions) has passed, the taxpayer did not have a US abode and was physically present outside the United States for at least 330 full days.

The test runs against any one of the three most recent tax years rather than requiring qualification across all three years. A UK-resident American who arrived in the UK during one of the streamlined years can still qualify if at least one of the three years had 330 days of foreign presence. The 330 days are full calendar days, with partial days in the US generally counted as US days for the test. Days spent in international airspace during travel do not count as US days.

The US abode requirement is separate from but interacts with the day count. US abode is determined by family ties, personal property, social and economic links, and other indicators of permanent attachment. A UK-resident American who has clearly relocated to the UK with family and primary economic ties in the UK does not maintain a US abode even if they hold a US property or US bank accounts. The IRS abode reference sits at https://www.irs.gov/individuals/international-taxpayers/figuring-the-foreign-earned-income-exclusion.

UK-resident Americans almost always satisfy the test through continuous UK residence across the streamlined years. Taxpayers with a mixed US and UK presence during the relevant years require careful day-counting analysis supported by documentation, including UK Home Office records, passport stamps, travel records, and UK utility bills.

The Non-Willful Conduct Standard

The second pillar is the non-willful conduct standard required for SFOP eligibility. The Form 14653 SFOP certification requires the taxpayer to certify under penalty of perjury that the failure to report all income, pay all tax, and submit all required information returns, including FBARs, was due to non-willful conduct.

The IRS willfulness framework, as articulated in Bedrosian v United States (3rd Cir 2018) and Bittner v United States (US Supreme Court 2023), distinguishes between non-willful conduct (negligence, inadvertence, mistake-based, or rooted in good-faith misunderstanding) and willful conduct (voluntary, intentional violation of a known legal duty or willful blindness amounting to reckless disregard). The framework rejects ordinary negligence as insufficient to support willfulness, requiring a higher mental state.

Several factual patterns support non-willful framing for UK-based Americans. A genuine lack of awareness of citizenship-based US taxation is common among taxpayers who moved to the UK as young adults or who hold US citizenship through a US-born parent without strong US connections. Reliance on UK-only accountants who never asked about US obligations is another common pattern. Purely transactional use of a foreign account without active concealment indicators supports a non-willful framing. Immediate action taken once the obligation is known, by engaging specialist advisers and initiating the SFOP submission, supports a non-willful framing.

Several factual patterns push toward willful framing and may disqualify the taxpayer from SFOP. Sustained patterns combined with a professional tax background appear concerning. Active concealment indicators, including structured transactions to avoid FBAR thresholds, deliberate non-disclosure to US-based advisers, or moving funds to avoid detection, appear concerning. Prior FBAR signature on a US tax return, followed by gaps suggesting awareness, then deliberate non-filing appears concerning. The IRS willfulness reference sits at https://www.irs.gov/irm/part4/irm_04-026-016.

The Scope: Three Years of Form 1040 and Six Years of FBARs

The third pillar covers the scope of the SFOP catch-up engagement. The framework requires three years of late-filed Form 1040 federal income tax returns, including all relevant schedules and information returns, plus six years of FinCEN Form 114 FBAR filings through the BSA E-Filing System.

The three Form 1040 years are the three most recent tax years for which the return due date (including extensions) has passed. Each Form 1040 captures worldwide income with Schedule B for foreign interest and dividend income, Schedule D for capital gains, Form 2555 Foreign Earned Income Exclusion under IRC Section 911 or Form 1116 Foreign Tax Credit under IRC Section 901, Form 8938 FATCA Statement of Specified Foreign Financial Assets under IRC Section 6038D where the threshold is met, Form 8621 Passive Foreign Investment Company reporting under IRC Section 1297 for each PFIC position, Form 3520 foreign trust and gift reporting under IRC Section 6048 where applicable, and Form 8833 treaty position disclosure under IRC Section 6114 where treaty positions affect the return.

The six FBAR years are the six most recent calendar years for which the FBAR due date has passed. Each FBAR covers all reportable foreign financial accounts where the aggregate balance exceeded $10,000 at any time during the calendar year. The FBAR captures year-end balance and peak balance for each account, converted to USD using the Treasury Reporting Rates of Exchange year-end rate.

How to Apply for Streamlined Foreign Offshore Procedures in the UK

Confirm SFOP eligibility through both pillars. Document the 330-day foreign residency test result for at least one of the three most recent tax years using passport stamps, UK Home Office records, travel records, and supporting evidence. Run the willfulness framing analysis against the IRS framework, identifying whether facts support non-willful framing under Bedrosian v United States. The IRS streamlined filing page sits at https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures.

Inventory all UK financial accounts across the past six calendar years. Capture UK current accounts, UK savings accounts, Cash ISAs, Stocks and Shares ISAs, NS&I Premium Bonds and other NS&I products, UK building society accounts, UK workplace pensions, UK SIPPs, UK foreign brokerage accounts, and any other UK-held financial accounts with year-end and peak balances for each calendar year. Gather six years of statements for the FBAR catch-up and three years of statements for the Form 1040 returns.

Run the PFIC analysis on any UK Stocks and Shares ISA holdings. UK-domiciled funds, investment trusts, and ETFs typically qualify as PFICs under IRC Section 1297. Form 8621 reporting applies to each PFIC position across the three streamlined Form 1040 years, with the IRC Section 1291 excess distribution tax framework calculated for each year. Coordinate liquidation with US-licensed investment advisers where appropriate to stop further PFIC tax accrual prospectively.

Run the FEIE versus FTC election analysis for each of the three streamlined years. The 2025 FEIE threshold under IRC Section 911 is approximately $130,000 with an annual inflation adjustment. For UK marginal tax rates of 40 percent or higher, Foreign Tax Credit on Form 1116 typically outperforms FEIE because the higher UK tax provides full FTC absorption of US tax. Select the optimal election for each year.

Prepare three years of Form 1040 returns with all relevant schedules and information returns. Each return captures worldwide income with Schedule B, Schedule D for capital gains where relevant, Form 2555 or Form 1116, Form 8938 where applicable, Form 8621 for PFIC positions, Form 3520 for foreign gifts or trusts, and Form 8833 for UK pension treaty positioning under Article 17 of the US-UK Income Tax Convention 1975.

Prepare six years of FBAR returns through the BSA E-Filing System. Each FBAR covers all reportable foreign financial accounts with year-end and peak balances converted to USD using the Treasury Reporting Rates of Exchange. Include the streamlined explanation reference per IRS guidance in the BSA E-Filing System reference field. The FinCEN BSA E-Filing reference sits at https://bsaefiling.fincen.treas.gov/.

Draft the Form 14653 non-willfulness certification. The narrative addresses why the prior US filings were not completed, the timeline of awareness of US obligations, the source of awareness, the reason for prior non-compliance, and the steps taken once aware. The certification is signed under penalty of perjury and serves as the legal foundation for the SFOP submission.

Mail the comprehensive Form 1040 submission package to the IRS Streamlined Filing Center in Austin, Texas. The package includes the three years of Form 1040 returns with all schedules and information returns, the Form 14653 certification, and a covering letter referencing the SFOP route. Payment of any underlying US tax plus statutory interest under IRC Section 6601 accompanies the package.

File the six FBARs through the BSA E-Filing System. The FBARs are filed electronically, separately from the Form 1040 submission, but reference the same streamlined route in the explanation field per IRS guidance.

Monitor post-submission for any IRS follow-up correspondence. Most submissions are accepted without inquiry, with the IRS issuing no formal acceptance letter (the absence of follow-up over 6-12 months is the signal of acceptance). Some submissions trigger IRS information requests or examinations that require a specialist response.

Real-World Example: Streamlined Foreign Offshore Procedures in the UK in Practice

Case Study: An American Doctor Who Used SFOP After Twelve Years of UK Residence

Rebecca is a fictional but representative profile based on a typical US-UK Tax engagement. She is a US citizen who moved to London in 2013 to take an NHS specialist registrar role and progressed to NHS Consultant Psychiatrist by 2024, earning a base salary of £108,000 plus approximately £75,000 in private practice income annually. Her UK financial accounts included a Lloyds current account, a Santander joint account with her UK husband, a Hargreaves Lansdown Stocks and Shares ISA accumulated since 2015 containing UK-domiciled Vanguard and Fundsmith holdings with peak balance £142,000, a Cash ISA at Nationwide with balance £45,000, her NHS pension scheme with notional value approximately £285,000, and a small US-domiciled IRA from her medical school years with balance $48,000. She had never filed a US tax return in any year since moving to the UK in 2013.

She became aware of US filing obligations in February 2026 after a conversation with a US-based friend who mentioned FATCA. She received a FATCA letter from Lloyds in early March 2026 asking about her US person status. The combination prompted her to engage specialist support immediately.

Our diagnostic confirmed clear SFOP eligibility. The 330-day foreign residency test was easily met through continuous UK residence since 2013 across all three streamlined years. The non-willful framing was strongly supportable through Rebecca's NHS medical background being entirely distinct from tax professional expertise, her genuine lack of awareness of citizenship-based US taxation typical of US citizens who moved abroad early in their career, her reliance on UK PAYE compliance, which she had assumed covered all obligations, and her immediate action once aware in February 2026.

The technical analysis identified several specific items. The Hargreaves Lansdown Stocks and Shares ISA contained four UK-domiciled funds that required Form 8621 PFIC analysis under IRC Section 1297, with approximately $8,600 in IRC Section 1291 tax across the three streamlined years (2022, 2023, 2024). The NHS pension qualifies as a UK government-sponsored pension under Article 17(1) of the US-UK Income Tax Convention 1975, with Form 8833 treaty positioning protecting the notional growth from current US taxation. The FEIE versus FTC analysis identified Foreign Tax Credit on Form 1116 as the optimal election given Rebecca's combined UK income exceeding £180,000, placing her in the 45 percent additional rate band. Private practice income must be reported on Schedule SE under IRC Section 1401, with the US-UK Totalisation Agreement under Article 17, and HMRC Form CA3837, Certificate of Coverage, protecting against US self-employment tax exposure.

The SFOP submission was prepared over five months from February to July 2026. The three years of Form 1040 returns captured worldwide income, including NHS PAYE, private practice income with Schedule C and Schedule SE, plus Totalisation treaty positioning, UK interest income from Cash ISA and joint savings, Hargreaves Lansdown PFIC positions on Form 8621, and Form 8938 FATCA disclosure, given the aggregate UK balances exceeding $300,000 by the end of 2024. The six years of FBARs through the BSA E-Filing System covered all five UK accounts plus the NHS pension. The Form 14653 narrative addressed Rebecca's medical professional background, distinct from tax expertise; her UK PAYE compliance pattern; and her immediate action upon becoming aware.

The IRS acknowledged the submission without issuing a follow-up inquiry letter in late 2026. The integrated outcome was net additional US tax of approximately $8,600 across three years (primarily the PFIC tax), zero FBAR penalty (avoided $60,000+ exposure under per-report Bittner methodology), zero failure-to-file penalty under IRC Section 6651, zero Form 8938 FATCA penalty under IRC Section 6038D, and clean US compliance going forward with the NHS pension treaty positioning in place. Total US-UK Tax fees: approximately £7,200 for the SFOP engagement plus £2,000 for ongoing annual compliance setup. Rebecca's reflection: "The FATCA letter was frightening because I had no idea any of this existed. The SFOP route eliminated potential penalty exposure that could have run into hundreds of thousands of pounds for the cost of the underlying PFIC tax I would have owed anyway, plus the specialist fee."

Common Mistakes UK Expats Make With Streamlined Foreign Offshore Procedures UK

Delaying engagement after receiving a FATCA letter from a UK bank. The SFOP route is only available before IRS contact. FATCA-triggered IRS contact removes SFOP eligibility and pushes the case into the Voluntary Disclosure Practice framework with substantially higher penalty exposure or into examination with full statutory penalty assessment.

Using a generic Form 14653 non-willfulness narrative. The refined 2026 IRS Large Business and International Division review focuses on specific factual accounts addressing the timeline of awareness, the source of awareness, the reason for prior non-compliance, and the steps taken once awareness was gained. Generic narratives attract scrutiny and potential rejection. Specialist narrative drafting addressing the specific factual circumstances produces stronger submissions.

Missing the PFIC analysis on UK Stocks and Shares ISAs. UK-domiciled funds held in ISAs qualify as PFICs under IRC Section 1297, with punitive IRC Section 1291 tax treatment. The SFOP submission requires Form 8621 reporting for each PFIC position across the three streamlined Form 1040 years. Missing PFIC positions create compliance gaps that can trigger IRS examination after the SFOP submission appears to be accepted.

Selecting the wrong FEIE versus the FTC election. The default FEIE election under IRC Section 911, with the 2025 threshold of approximately $130,000, imposes hard caps that limit the value for higher-earning UK expats. The Foreign Tax Credit on Form 1116 typically outperforms the FEIE for UK marginal tax rates of 40 percent or higher because the higher UK tax allows full FTC absorption of US tax on UK-source income.

Missing the Form 8833 treaty positioning for UK workplace pensions. Without the treaty positioning under Article 17 of the US-UK Income Tax Convention 1975, the UK pension growth is currently US-taxable. The retrospective Form 8833 filing through the SFOP submission protects the pension growth across the three streamlined years and going forward.

Filing the SFOP submission without specialist support. The combination of multiple schedules, information returns, the BSA E-Filing System reference, the Form 14653 certification signed under penalty of perjury, and the technical analysis covering PFIC, treaty positioning, and FEIE versus FTC election produces complexity that benefits from specialist execution. The IRS streamlined filing page sits at https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures.

How US-UK Tax Can Help You With Streamlined Foreign Offshore Procedures UK

US-UK Tax is led by chartered tax advisers holding CTA status with the Chartered Institute of Taxation or ACCA professional accountancy status on the UK side, combined with IRS Enrolled Agent and US CPA credentials on the US side. The IRS Enrolled Agent credential under Circular 230 provides direct representation rights before the IRS for SFOP submissions and any follow-up examinations or appeals to the IRS Independent Office of Appeals.

Engagements run across three streams. First, the SFOP diagnostic covering the 330-day foreign residency test confirmation with supporting documentation, the willfulness framing analysis against the IRS framework as articulated in Bedrosian v United States and Bittner v United States, the comprehensive inventory of UK financial accounts across the past six calendar years, the PFIC analysis on any UK ISA fund holdings, the UK pension positioning under US-UK Income Tax Convention Articles 17 and 18, the FEIE versus Foreign Tax Credit election analysis, the FA 2025 long-term residence framework interaction, and a written engagement letter. Second, the SFOP submission execution covering the three years of Form 1040 returns with all relevant schedules and information returns, the six years of FBARs filed through the BSA E-Filing System with comprehensive UK account coverage, the Form 14653 non-willfulness narrative drafted with specialist review, the PFIC liquidation coordination with US-licensed investment advisers, the full coordination of payment of any tax owed plus statutory interest, and ongoing IRS correspondence handling. Third, the post-SFOP ongoing annual compliance with integrated US Form 1040 preparation, FATCA reporting, treaty positioning under Form 8833, ongoing FBAR filings, and integrated cross-border specialist support.

For more on how we work, see our Streamlined Filing Compliance Procedures service and our FBAR Penalty Defense service. Get in touch with our team today at or 0333-8807974 to discuss your situation.

Conclusion

Three takeaways. First, the Streamlined Foreign Offshore Procedures UK route is the right catch-up framework for UK-based Americans with non-willful missed US filings, providing a complete waiver of FBAR penalty under 31 USC 5321, failure-to-file penalty under IRC Section 6651, Form 8938 FATCA penalty under IRC Section 6038D, Form 8621 PFIC reporting failure penalty, and miscellaneous offshore penalty, with the taxpayer paying only the underlying US tax owed plus statutory interest from the original due date. Second, eligibility rests on two pillars: the 330-day foreign residency test in at least one of the three most recent tax years and the non-willful conduct standard under the IRS willfulness framework, as articulated in Bedrosian v United States and Bittner v United States. Third, the 2026 context, including FATCA enforcement maturity, a refined RS LB&I review, and the FA 2025 long-term residence framework, has materially increased the time sensitivity of the SFOP route, easing FA-triggered IRS contact removals that affect SFOP eligibility. Get in touch with our team today at or 0333-8807974 to discuss your situation.

FAQs

Q: Who qualifies for the Streamlined Foreign Offshore Procedures?

Eligibility for the SFOP route rests on three core conditions. First, a US person is a US citizen, Ga a green card holder, or Ua a S resident under the Substantial Presence Test under IRC Section 7701(b). Second, the foreign residency test requires physical presence outside the US for at least 330 full days in one of the three most recent tax years for which the return due date has passed. Third, non-willful conduct in the prior non-compliance under the IRS willfulness framework as articulated in Bedrosian v United States and Bittner v United States. UK-resident Americans almost always qualify. The IRS streamlined filing page sits at https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures.

Q: What is the 330-day foreign residency test for SFOP?

The 330-day foreign residency test requires the taxpayer to be physically present outside the United States for at least 330 full days in one of the three most recent tax years for which the US tax return due date has passed and not to have a US abode. The 330 days are full calendar days, with partial days in the US generally counted as US days. The test runs against any one of the three years rather than requiring qualification across all three. UK-resident Americans with continuous UK residence easily clear the threshold.

Q: What does non-willful conduct mean under SFOP?

The non-willful conduct standard under the IRS willfulness framework, as articulated in Bedrosian v United States (3rd Cir 2018), covers negligence, inadvertence, mistake-based behavior, or is rooted in good-faith misunderstanding. Willful conduct includes voluntary, intentional violation of a known legal duty or willful blindness amounting to reckless disregard. The framework rejects ordinary negligence as insufficient to support willfulness, requiring a higher mental state. Common non-willful patterns for UK-based Americans include a genuine lack of awareness of citizenship-based taxation and reliance on UK-only accountants who never asked about US obligations.

Q: How many years of returns and FBARs does SFOP require?

SFOP requires three years of late Form 1040 federal income tax returns with all relevant schedules and information returns, plus six years of FinCEN Form 114 FBAR filings through the BSA E-Filing System. For submissions made during 2026, the typical three Form 1040 years are 2022, 2023, and 2024, and the six FBAR years are 2019 through 2024. The IRS framework fixes the scope.

Q: Do I have to pay any penalty under SFOP?

No. SFOP carries zero FBAR penalty under 31 USC 5321, zero failure-to-file penalty under IRC Section 6651, zero failure-to-pay penalty, zero Form 8938 FATCA penalty under IRC Section 6038D, zero Form 8621 PFIC reporting failure penalty under IRC Section 1298(f), and zero miscellaneous offshore penalty for qualifying non-willful UK-based Americans. The taxpayer pays only the underlying US tax owed plus statutory interest under IRC Section 6601 from the original due date.

Q: What is the Form 14653 SFOP certification?

Form 14653 is the SFOP non-willfulness certification required for all SFOP submissions and must be signed under penalty of perjury. The certification addresses why the prior US filings were not completed, the timeline of awareness of US obligations, the source of awareness, the reason for prior non-compliance, and the steps taken once aware. The 2026 IRS Large Business and International Division review screens for generic narratives, making specialist drafting addressing specific factual circumstances materially important.

Q: How long does an SFOP submission take to complete?

A typical SFOP engagement runs three to five months from initial diagnostic through final IRS submission. The timeline includes the initial diagnostic (1-2 weeks), comprehensive financial information gathering (3-4 weeks), PFIC analysis and remediation coordination (2-4 weeks), three years of Form 1040 preparation (4-6 weeks), six years of FBAR preparation (1-2 weeks), Form 14653 narrative drafting (2-3 weeks), and submission package preparation and mailing (1-2 weeks). Complex cases with multiple PFIC positions or borderline willfulness framing can extend the timeline by 1-2 months. The IRS Voluntary Disclosure Practice reference sits at https://www.irs.gov/compliance/criminal-investigation/voluntary-disclosure-practice.

Q: Can US-UK Tax handle my SFOP engagement end-to-end?

Yes. This is our core specialism. We hold combined UK CTA/CIOT or ACCA credentials plus IRS Enrolled Agent or US CPA credentials, enabling genuinely integrated handling of the full SFOP engagement. The engagement covers the initial diagnostic, the willfulness framing analysis, the three years of Form 1040 preparation with all relevant schedules and information returns, the six years of FBARs through the BSA E-Filing System, the Form 14653 narrative drafting, the comprehensive submission package preparation, direct IRS representation under Circular 230 through any follow-up, and post-SFOP ongoing annual compliance. Get in touch at or 0333-8807974 to discuss your situation.