Most people qualify as non-willful — and can catch up safely

Streamlined Filing & Voluntary Disclosure

Found out about FBAR, PFIC, or foreign-property rules years too late? You are not alone, and you are not stuck. The IRS Streamlined Procedures and the CRA Voluntary Disclosures Program let non-willful taxpayers get fully current with reduced or no penalties — if you come forward first.

See If I Qualify Compare the Programs
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Quick answer

How do I catch up on missed FBAR and foreign-asset filings without large penalties?

If you only just learned about FBAR, PFIC, or foreign-property rules, you are not stuck — but the path depends on coming forward before the IRS or CRA contacts you. For non-willful US taxpayers, the IRS Streamlined Filing Compliance Procedures let you file the last three years of returns and six years of FBARs with a reduced penalty, and often zero for those who qualify under the foreign-resident version. On the Canadian side, the CRA Voluntary Disclosures Program can waive penalties and partial interest for taxpayers who disclose first. The decisive factor is being non-willful — an honest misunderstanding rather than deliberate hiding. Acting before you receive a notice is what protects you; once an audit or examination begins, these programs generally close. We assess whether you qualify, prepare the catch-up filings, and draft the non-willful certification that supports your case.

The Catch-Up Programs

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IRS — United States

  • →Streamlined Foreign Offshore Procedures — for those living abroad; 3 years of returns, 6 years of FBARs, offshore penalty waived.
  • →Streamlined Domestic Offshore Procedures — for US residents; a 5% miscellaneous offshore penalty applies.
  • →Delinquent FBAR Submission Procedures — when only FBARs are missing and income was reported.
  • →Delinquent International Information Return Procedures — for missed 5471, 5472, 8865, 3520, and similar.
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CRA — Canada

  • →Voluntary Disclosures Program (VDP) — correct unreported income or omissions before the CRA contacts you.
  • →Relief from penalties and partial interest where the disclosure is accepted as valid.
  • →Commonly used for late T1135 foreign property reporting and unreported foreign income.
  • →Coordinated with the US side so both countries are fixed together, not in isolation.

How We Run a Catch-Up

  • Assess your facts and confirm a non-willful position before anything is filed
  • Reconstruct the required years of returns, FBARs, FATCA, and PFIC forms
  • Draft the non-willfulness certification or VDP submission that supports your relief
  • Coordinate the US and Canadian filings so credits and positions reconcile
  • Set you up to stay compliant going forward with a simple annual plan

Why now beats later: these programs generally require coming forward before the IRS or CRA opens an examination. Voluntary, well-documented catch-up is routinely the difference between full penalty relief and a much harder, costlier process.

Catch-Up FAQs

What are the Streamlined Procedures?
An IRS amnesty path for non-willful taxpayers. The Foreign Offshore version (for those abroad) requires 3 years of amended returns and 6 years of FBARs with a non-willfulness certification and waives the offshore penalty; the Domestic version carries a 5% penalty.
What is the Canadian VDP?
The CRA Voluntary Disclosures Program lets you correct past Canadian filings before the CRA contacts you, often with penalty relief and partial interest relief. It covers unreported income and late T1135 foreign-property reporting.
How do I know if I was non-willful?
Non-willful usually means negligence, a misunderstanding, or simply not knowing the rules, rather than intentionally hiding income or accounts. Most people who learn the rules late qualify. We assess your facts before recommending a path.
What if they contact me first?
Eligibility generally requires coming forward before an examination opens, which is why acting now matters. If you have already received a notice, different procedures apply and we will advise on the best remaining option.

Fix the Past Before It Finds You

A confidential call covers what you missed and the cleanest, lowest-penalty way back into compliance. No commitment.

info@ilmcpa.com +1 (206) 209-8210