Nobody Asked About the Overseas Account
Your account was opened in another country, during another chapter of life, when there was no reason to think it would ever become a US tax problem.
Then you moved back. The account stayed open. And at some point, someone mentioned FBAR.
The IRS Has a Name for What Happened to You
There is a formal distinction between missing a reporting requirement because you did not know it existed and missing it because you were trying to conceal something. The IRS treats those two situations completely differently.
Streamlined Domestic Offshore Procedures exist for the first kind. Non-willful means confusion, unfamiliarity with US rules, or a prior preparer who never asked. The path is defined: amended returns, FBAR filings, one consolidated penalty.
The penalty is calculated against the highest combined foreign account balance across the covered years. It is a real number, but a controlled one.
Having the IRS identify the accounts first removes the program entirely. What replaces it is standard enforcement, with no penalty ceiling and no defined path out.
Get the Numbers Before You Decide Anything
The exposure almost always feels larger before anyone runs the actual calculation. Most people who begin a consultation expecting significant liability end up with a number far more manageable than what they had been carrying in their heads for months.
The package under the streamlined filing compliance procedures covers three years of amended federal returns, six years of late FBAR filings, and the offshore penalty calculation.
It also requires a signed narrative explaining why the accounts were not reported. That document has to hold together under review. Vague explanations and incomplete timelines are not options.
The Certification Has to Hold Together
The non-willful certification, Form 14654, is not a checkbox. It is a signed statement built from the actual record of what happened and why.
Language that lacks specificity creates problems. Timelines that do not align with the account history create problems. The certification and the amended returns are built together at Maris, from the same documents, so the package reads as one coherent explanation rather than forms attached to a statement that does not quite match them.
An international tax accountant at the CPA level carries IRS representation authority. If the submission draws scrutiny, we answer for it directly. That accountability does not end at the filing date.
We handle SDOP cases for US residents in Everett and across the country: inherited accounts, expat banking relationships that stayed open after a relocation, unreported foreign income from investments that were never added to a US return.
The Longer You Wait, the Fewer Options There Are
SDOP is available until the IRS begins a formal examination of the relevant years. At that point, the program closes for those years and does not reopen. FATCA has made data sharing between foreign financial institutions and the IRS far more complete than most clients realize.
Acting before contact puts you in a position to control the process, the narrative, and the outcome. Waiting places all three of those somewhere else.
This Is Easier to Start Than It Looks
Most people who call have been sitting with this for a while. The situation feels complicated. The right moment to address it never quite arrives.
Once the engagement starts, most clients say the same thing: it moved faster than they expected. Filed and accepted, it is behind them.
Contact Maris & Associates CPAs. We will review the facts, run the actual numbers, and tell you exactly where things stand.