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Delancy CPA · IRS Offshore Disclosure & Catch-Up

Behind on foreign reporting? There's a legal way back.

Foreign accounts you never reported. FBARs you'd never heard of. A company back home the IRS doesn't know about. If your mistake was honest, the IRS has amnesty programs built for exactly this — and most people who use them pay little or no penalty. No judgment here. Just the way back.

Cross-border CPA · fixed fees published below · English, Español & Português

Take a breath. Here's the truth:

  • You are not a criminal. Honest, non-willful mistakes have a dedicated IRS path with reduced or zero penalties.
  • You found this before the IRS found you — that's the single thing that matters most.
  • Most catch-ups are 3 years of returns and 6 years of account reports. Bounded, fixable, done.
  • Your situation is almost certainly not the worst we've seen this month.
The trade the IRS is offering

What the amnesty programs replace.

If the IRS finds you first, penalties stack per account, per form, per year. If you come forward first through the streamlined procedures, the entire stack is replaced with one small penalty — or none at all.

If the IRS finds you first

The penalty stack

  • FBAR: $10,000+ per account, per year — far higher if treated as willful
  • $10,000+ per missed information form (foreign company, trust, assets), per year
  • Accuracy penalties up to 20% — civil fraud up to 75%
  • Streamlined door closes permanently the day they contact you
If you come forward first

The streamlined trade

  • Lived abroad? 0% offshore penalty — pay only the back tax and interest
  • U.S. resident? One penalty of 5% of the unreported accounts' year-end peak — instead of the stack
  • Only FBARs missed, income all reported? Often no penalty at all
  • Done once, properly — then you're simply a normal taxpayer again
The window is real, and it isn't yours to control. The streamlined programs remain open in 2026, but the IRS can end them with a press release — and foreign banks already report U.S. account holders automatically under FATCA. Eligibility ends the moment the IRS contacts you first. Coming forward is a race you only win by starting.
60-second self-triage

Which path fits you?

Three questions. No email required, nothing is recorded — this runs entirely on your screen. It points you to the likely program; the Disclosure Assessment confirms it.

Question 1 of 3

Has the IRS already contacted you about foreign accounts, foreign income, or missing returns?

Question 2 of 3

Was there foreign income that never made it onto a U.S. return — interest, rent, salary, business profit, anything?

Question 3 of 3

In at least one of the last three years, did you live outside the U.S. for most of the year (roughly 330+ days)?

Your likely path
Delinquent FBAR submission
$1,750 flat · typically no penalty

If all your income was reported and only the account reports (FBARs) were missed, you generally don't need the full streamlined program. Six years of FBARs plus a properly drafted explanation statement — filed, done, back in good standing.

One caution: "all income was reported" has to actually be true, down to the bank interest. The Assessment verifies that before anything is filed — because filing the wrong path is worse than filing late.

Your likely path
Streamlined Foreign Offshore (SFOP)
from $4,500 flat · 0% offshore penalty

For non-willful taxpayers who meet the foreign-residency test: three years of returns, six years of FBARs, and a certification of non-willful conduct. The offshore penalty is zero — you pay the back tax and interest, and you're clean.

The certification narrative is the heart of the submission — it's a sworn statement, and it's where professional drafting earns its fee. If your catch-up years include a foreign company, trust, or PFIC funds, the fee is quoted after the Assessment (typically $9,500–$15,000 — and we're one of the few firms built for exactly that).

Your likely path
Streamlined Domestic Offshore (SDOP)
from $6,500 flat · one 5% penalty replaces the stack

For non-willful U.S. residents: three amended returns, six years of FBARs, a certification of non-willful conduct, and one Title 26 penalty of 5% of the highest year-end balance of the unreported accounts — instead of penalties stacking per account, per form, per year.

Computing that 5% base correctly is real analytical work — what's in, what's out, which year — and it's part of the fixed fee. If your catch-up years include a foreign company or PFIC funds, the fee is quoted after the Assessment (typically $9,500–$15,000).

Your situation
The voluntary window may have closed — but you still have moves.

Once the IRS makes first contact, the streamlined programs are generally off the table. What remains: responding correctly to the notice, penalty-abatement requests for reasonable cause, and — where the facts warrant it — representation. The worst move now is silence; the second-worst is responding without reading the notice's deadlines.

Book a call and bring the notice. We'll tell you plainly what it is, what it isn't, and whether you need a CPA, an attorney, or both.

Fixed fees, published

What it costs — in writing, before you commit.

Panic is expensive; we'd rather you shop calmly. These are the standard fixed fees. Your exact quote — one number, in writing — comes out of the Disclosure Assessment.

FBAR catch-up

All income was reported — only the account reports were missed. 6 years of FBARs + explanation statement.
$1,750 flat

Streamlined Foreign

Lived abroad. 3 returns + 6 FBARs + non-willful certification. 0% offshore penalty.
$4,500 flat

Streamlined Domestic

U.S. resident. 3 amended returns + 6 FBARs + certification + the 5% penalty-base computation.
$6,500 flat
Foreign company, trust, or PFIC funds in the catch-up years? That's our specialty — the cases the volume shops can't take and the law firms overcharge for. Amended years that include Form 5471, 8621, or 3520 work are quoted as a single fixed fee after the Assessment, typically $9,500–$15,000.
Every engagement starts with the Disclosure Assessment — $950. A structured interview and document review: eligibility, program selection, a non-willfulness screen, an estimate of any 5% penalty, and your fixed-fee quote. It credits in full toward your engagement within 60 days.
Book the Assessment
How it works

Three steps. Then it's behind you.

1

Assessment

One structured call plus document review. We confirm your eligibility, pick the right program (not the biggest one), estimate any penalty, and quote one fixed fee.

2

Preparation

We build the full submission — returns, FBARs, the certification narrative, the penalty computation — and walk you through every page before anything is signed.

3

Submission & after

Filed correctly, once. Then we set up your simple, ordinary go-forward filings so this never happens again — your Assessment fee already credited.

Two things we'll always tell you straight. First: if a smaller path fits — a simple FBAR catch-up instead of a full streamlined package — that's what we'll recommend, at the smaller fee. Second: the streamlined programs require certifying, under penalty of perjury, that your conduct was non-willful. If your facts don't support that, we will tell you, and we'll connect you with experienced tax counsel — that conversation is confidential, and it's the one that protects you most.
Not actually behind on anything? If your past filings are clean and you just need to understand your cross-border situation — a new move, a foreign company, a decision in front of you — the right starting point is our 60-minute Orientation Session ($750 flat, credited toward any engagement), not a disclosure filing.

The worst version of this is the one where they find you first.

The programs are open. You're still eligible. One assessment, one fixed fee, one properly built submission — and you're simply a normal taxpayer again.

Book your Disclosure Assessment — $950