If you didn't know you had to file, the IRS Streamlined Foreign Offshore Procedures let you catch up by filing your last 3 years of tax returns and 6 years of FBARs, with a signed statement (Form 14653) that the failure was not willful. You pay any tax and interest due. There are no penalties.
Because Canadian tax usually offsets US tax, many people catching up owe nothing at all.
Why so many Americans in Canada are behind
The US taxes its citizens and green card holders wherever they live. Canada doesn't work that way, so people who moved north years ago, or who were born in Canada to an American parent, often never hear about it. They find out from a bank asking about US citizenship, a news story, or a parent.
The IRS knows this. Its Streamlined Filing Compliance Procedures are for taxpayers whose failure to file was non-willful. The version for people living outside the US, the Streamlined Foreign Offshore Procedures, is the one that applies to most Americans living in Canada.
Do you qualify?
You can generally use the Streamlined Foreign Offshore Procedures if all of these are true:
Many Americans born or raised in Canada never got a Social Security number. You'll need one before you file; you apply through the US Social Security Administration.
What you file
How the package is sent
- Write "Streamlined Foreign Offshore" in red at the top of each return and information return.
- Mail the returns and Form 14653 on paper, and pay the tax and interest due. Electronic submissions of the returns are not accepted. The IRS address is: Internal Revenue Service, 3651 South I-H 35, Stop 6063 AUSC, Attn: Streamlined Foreign Offshore, Austin, TX 78741.
- File the FBARs online yourself. On each one, choose "Other" as the reason for filing late and enter "Streamlined Filing Compliance Procedures".
Which years apply right now
The window moves with the date you submit. A return counts once its due date has passed: June 15 for someone living abroad (the automatic extension), or October 15 if you filed Form 4868. An FBAR counts once it is late, after October 15 of the following year. For a package submitted between October 16, 2026 and June 15, 2027, it is:
After June 15, 2027, the 2026 return can enter the window and 2023 can drop out (the 2026 FBAR joins after October 15, 2027). Lou works out the exact years from today's date and asks about an extension when it matters. If you submit close to one of these dates and are unsure, ask a professional which years apply.
What it costs you
Under the foreign procedures there are no failure-to-file or failure-to-pay penalties, no accuracy penalties, no information return penalties and no FBAR penalties. You pay only the tax due on the three returns, plus interest.
For most Americans in Canada the tax is small or zero. Canadian income tax is usually higher than US tax on the same income, and the foreign tax credit applies to catch-up years like any other year. Where tax does come up, it is usually from income Canada doesn't tax: TFSA earnings, Canadian funds, or Home Buyers' Plan withdrawals.
Your RRSP is protected
People who never filed can't technically make the RRSP and RRIF deferral election on time. The IRS says Streamlined filers get relief consistent with Rev. Proc. 2014-55 (Streamlined FAQ 3), so the growth inside your RRSP stays tax-deferred. See RRSP and RRIF.
Writing your Form 14653 statement
Form 14653 is signed under penalties of perjury. Its key part is your own explanation of why you didn't file. The IRS wants specific facts, not a formula: when you moved or were born abroad, what you knew about US filing, how you found out, and what you did next.
Write it in your own words and keep it true. A professional is worth it here if your facts are mixed, for example if you once received an IRS letter or an advisor told you about filing years ago.
When to talk to a professional first
The Streamlined procedures rely on your certification that you were non-willful, and the IRS can audit any Streamlined submission. Get advice before filing if any of these apply:
- You knew about the US filing or FBAR rules and didn't follow them.
- You have had letters or contact from the IRS about these years.
- Large balances, foreign corporations, partnerships or trusts beyond registered accounts.
- A business with employees, rental properties, or an estate.
- You are considering giving up US citizenship. That has its own rules.
Penalties the IRS already assessed before you file are not removed by the procedure.