What if I have never filed U.S. taxes while living in Denmark?

That is the ordinary case this programme exists for. A qualifying taxpayer files the most recent 3 years of returns and the most recent 6 years of FBARs with a 0% offshore penalty. Because Danish tax rates are high, the Foreign Tax Credit often leaves little or no U.S. tax on employment income across those years — but the filings themselves are still required.

Will I owe a lot of U.S. tax after catching up from Denmark?

On employment income, often little or nothing, because Danish income tax generally exceeds the U.S. tax on the same income and the Foreign Tax Credit offsets it. Investment income is where balances more often appear, particularly if Danish or European funds fall under the §1291 default with its interest charge.

Do my Danish investment funds have to be dealt with in the catch-up?

If they are PFICs, yes — the reporting applies to each year in the window, generally one Form 8621 per PFIC per year. This is usually the largest part of the work in a Danish Streamlined case, and it is worth scoping before you start.

Is there a deadline for Streamlined?

There is no published deadline, but eligibility ends once the IRS contacts you about the years concerned. Denmark reports U.S. account holders under the FATCA intergovernmental agreement, so waiting is not neutral.

Does Atamatax file the Streamlined submission for me?

No. Atamatax prepares the return package — the year-by-year Forms 1040, the Form 1116 credit for Danish tax, Form 8621 for PFICs, and FBAR values with instructions. You write and sign Form 14653 in your own words, assemble the mailing from the package's instructions, and file.

Topic · Denmark

Streamlined filing from Denmark: catching up on US taxes

Americans in Denmark who have never filed are usually non-willful, usually owe little after the Foreign Tax Credit, and usually have a penalty-free route back.

By Danilson Ramos · Founder, Atamatax

Published August 2026 · Updated September 2026

Key takeaways

The Streamlined Foreign Offshore Procedures cover the most recent 3 years of tax returns and the most recent 6 years of FBARs, with a 0% offshore penalty for taxpayers who qualify.
Two gates control eligibility: conduct must have been non-willful, and the non-residency test — no US abode and at least 330 full days outside the United States, in at least one of the last three years for which the return due date has passed.
Denmark's high effective tax rates mean the Foreign Tax Credit frequently reduces the U.S. tax due on employment income to zero or near it — but the returns still have to be filed.
PFIC holdings from a Danish broker or Aktiesparekonto are usually what makes a Danish catch-up more work than the return itself.
There is no IRS deadline to come forward, but the programme is only available before the IRS contacts you about it.

Part of the Denmark desk — every US tax topic for Denmark in one place.

Start here

You don't need every document to take the first step.

One question to start, three more to sharpen it — answered here, with no email. Your answers carry into the eligibility screening rather than being asked again.

Free, no account, nothing you answer leaves this page. Open the full eligibility checker

Four answers give a first read on the published gates; eligibility follows from your full facts. Non-willfulness is your own certification on Form 14653 — a statement only you can make.

The typical story in Denmark is not tax evasion. It is someone who moved for a job or a Danish partner, paid a lot of Danish tax for years, and discovered the U.S. filing obligation from a bank letter, a colleague, or a passport renewal. That is the profile the Streamlined Foreign Offshore Procedures were designed for.

Who the programme is for

The Streamlined Foreign Offshore Procedures let a qualifying U.S. person living abroad file the most recent 3 years of delinquent or amended returns and the most recent 6 years of FBARs, with the offshore penalty set at 0%. Two conditions gate it: your failure to file must have been non-willful, and you must meet the non-residency test — no US abode and at least 330 full days outside the United States, in at least one of the last three years for which the return due date has passed.

Willfulness is a legal judgement about your state of mind, not a checkbox. You certify it yourself on Form 14653, under penalty of perjury. If there is any real question, that is a conversation with a tax attorney, not with software.

Why the Danish case usually ends near zero tax

Denmark's combined municipal and state income tax, with labour-market contributions, produces an effective rate on employment income that generally exceeds the U.S. rate on the same income. The Foreign Tax Credit on Form 1116 credits qualifying Danish income tax against U.S. tax on the same income, category by category. For a salaried American in Denmark, that commonly leaves little or no U.S. tax on employment income across the catch-up years.

That is the good news and the trap in the same sentence. Owing nothing does not remove the requirement to file, and the penalties that attach to unfiled information returns — the FBAR, Form 8938, Form 8621 — attach regardless of whether tax was due.

What actually makes a Danish catch-up complicated

Danish and European funds in a Saxo, Nordnet or bank portfolio. Each PFIC generally needs its own Form 8621, for each year in the catch-up window, under the §1291 default.
An Aktiesparekonto opened since 2019. Whatever is inside it has to be classified holding by holding for every year covered.
Pension arrangements. Classification questions that are hard enough for one year get repeated across the window.
Six years of DKK peak balances. The FBAR years need each account's maximum value, converted at each year's December 31 Treasury rate.

What a Streamlined submission contains

the most recent 3 years of Forms 1040 with all required schedules and information returns
the most recent 6 years of FinCEN 114 filings, submitted electronically to FinCEN
Form 14653, certifying non-willfulness and the non-residency test, signed by you
Payment of any tax and statutory interest due with the returns

Atamatax prepares the return side: the year-by-year Forms 1040, the Form 1116 credit for Danish tax, the Form 8621 workload for any PFICs, and the FBAR values with filing instructions. It does not generate Form 14653, assemble the final mailing, or transmit anything to the IRS or FinCEN — those remain yours or your adviser's.

Timing

There is no statutory deadline to come forward, but the programme is closed to you once the IRS has initiated an examination or otherwise contacted you about the years in question. Danish institutions report U.S. account holders under the FATCA intergovernmental agreement, so the information flow does not wait for you.

Check whether the Streamlined route fits your facts

The free eligibility tool walks the residency and non-willfulness questions and gives a cautious indication of the fit; non-willfulness is your own certification.

Check my catch-up path

Done-with-youStreamlined Investor · $2,200

Rather have a human run the whole catch-up with you?

The Streamlined tiers are quoted in writing once the scope is confirmed, and you accept the quote before any payment. A call is free, optional and available at any point. Where the scope needs a conversation — an open willfulness question, an IRS examination, or facts the intake leaves open — it is offered before any price; otherwise the written quote comes straight from the intake. The exact years, the return/FBAR/Form 14653 deliverables, the price and who does what are all on the quote before you accept it. Booking does not purchase or guarantee a completed Streamlined package.

Book a free 15-min eligibility call What’s included

The call is free and is only a fit and scope check. Non-willfulness is your certification and may require advice from a qualified professional.

Your country

The gates are the same everywhere. From here:

How does the Streamlined route work?
Eligibility, scope, the three tiers and where to start.
Am I eligible for the foreign procedure?
The two published gates — non-residency and non-willfulness — decide it, and neither is assumed.
What will I certify on Form 14653?
Non-willfulness, in your own words, under penalties of perjury.
Is the procedure ending?
What the IRS has actually published, and when we last checked.
Do foreign ETFs or funds change the case?
A non-US fund adds a Form 8621 to every open year — the count decides the tier.
Check my catch-up path
Eight questions on the published gates, free, no account.

Authorities cited

IRS Streamlined Foreign Offshore Procedures — U.S. Taxpayers Residing Outside the United States — Streamlined Foreign Offshore Procedures
FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
IRS Form 1116 — About Form 1116 — Foreign Tax Credit (Individual, Estate, or Trust)
IRC §901 — IRC §901 — Taxes of foreign countries and U.S. possessions

Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.

Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.

Frequently asked questions

Can Americans living in Denmark use the Streamlined Filing Compliance Procedures?#: Living in Denmark does not by itself qualify or disqualify you. The Streamlined Foreign Offshore Procedures require that your failure to file was non-willful and that you meet the non-residency test — no US abode and at least 330 full days outside the United States, in at least one of the last three years for which the return due date has passed. Many long-term U.S. residents of Denmark meet both, but the facts have to be checked rather than assumed.
What if I have never filed U.S. taxes while living in Denmark?#: That is the ordinary case this programme exists for. A qualifying taxpayer files the most recent 3 years of returns and the most recent 6 years of FBARs with a 0% offshore penalty. Because Danish tax rates are high, the Foreign Tax Credit often leaves little or no U.S. tax on employment income across those years — but the filings themselves are still required.
Will I owe a lot of U.S. tax after catching up from Denmark?#: On employment income, often little or nothing, because Danish income tax generally exceeds the U.S. tax on the same income and the Foreign Tax Credit offsets it. Investment income is where balances more often appear, particularly if Danish or European funds fall under the §1291 default with its interest charge.
Do my Danish investment funds have to be dealt with in the catch-up?#: If they are PFICs, yes — the reporting applies to each year in the window, generally one Form 8621 per PFIC per year. This is usually the largest part of the work in a Danish Streamlined case, and it is worth scoping before you start.
Is there a deadline for Streamlined?#: There is no published deadline, but eligibility ends once the IRS contacts you about the years concerned. Denmark reports U.S. account holders under the FATCA intergovernmental agreement, so waiting is not neutral.
Does Atamatax file the Streamlined submission for me?#: No. Atamatax prepares the return package — the year-by-year Forms 1040, the Form 1116 credit for Danish tax, Form 8621 for PFICs, and FBAR values with instructions. You write and sign Form 14653 in your own words, assemble the mailing from the package's instructions, and file.

Related guides

Preparation · price before you start

If you want the missing years prepared

Which route fits depends on a few facts, not on the balances. These are the common situations and the route the same rules give each one. Nothing is charged until you generate a package or accept a written quote.

Several years unfiled; wages, pensions and bank accounts, no non-US funds
Streamlined Essential · $1,590 · Scoped by hand
Wages, pensions or bank accounts with no non-US funds is the standard catch-up scope: three returns, six FBARs, and the certification package.
What arrives, who prepares and checks it, and who files
A Streamlined Foreign Offshore preparation package: up to three delinquent returns and six FBAR years as worksheets mapped to each year's official forms (official PDFs for the current filing year), a document completeness check, the Form 14653 organiser, and filing instructions — one scoped quote, one payment.
A person at Atamatax prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures. You write your own statement of facts.
A person at Atamatax checks the package for completeness before release — an operational check, not a review by a credentialed tax professional. No EA or CPA review is included unless your written scope names one.
You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.
Get a scoped quote
The same, with non-US funds or a personal foreign pension
Streamlined Investor · $2,200 · Scoped by hand
The catch-up years include non-US funds or a personal foreign plan, so each back year needs PFIC work as well as the return and the FBAR.
What arrives, who prepares and checks it, and who files
A person at Atamatax prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures. You write your own statement of facts.
A person at Atamatax checks the package for completeness before release — an operational check, not a review by a credentialed tax professional. No EA or CPA review is included unless your written scope names one.
You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.
Get a scoped quote
The same, with a foreign company, a trust, or more than ten funds
Streamlined Complex · From $2,990 · Scoped by hand
Several unfiled years plus a foreign company, a trust or a large fund portfolio is the hand-scoped tier: the scope is set before any price is quoted, and a company or trust return is prepared by a specialist alongside the personal returns.
What arrives, who prepares and checks it, and who files
A person at Atamatax prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures. You write your own statement of facts.
A person at Atamatax checks the package for completeness before release — an operational check, not a review by a credentialed tax professional. No EA or CPA review is included unless your written scope names one.
You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.
Get a scoped quote
An IRS examination is open, or willfulness is an open question
Confirm the scope before choosing a package · Free to ask
The IRS has already been in contact. The published catch-up routes close once an examination is open, so the next step is a conversation about representation, not a filing package.
What arrives, who prepares and checks it, and who files
Free to ask. A person reads the facts and says whether Atamatax can take the case, and which route it would be.
A person at Atamatax reads the facts before any route is offered.
See whether Atamatax can take the case

When a professional's judgment is needed. An open IRS examination, a question about whether the missed years were willful, or an unsettled US status goes to a person before anything is quoted — those decide whether a catch-up procedure is available at all, and nothing should be certified under penalty of perjury until they are answered. Most IRS letters do not close a route; an examination does.

In every route the signatures and the filing stay with you or the accountant you choose; nothing is filed on your behalf. Written questions to hello@atamatax.com get a reply within one business day. Who does what in each route.

Free preliminary result · a few questions

Build your catch-up filing map

Answer a few questions about the years you missed and what you hold abroad. See which filings may apply, whether the Streamlined route looks consistent with your facts, and what to gather first.

Build my catch-up filing mapNo signup. Answers stay yours.

Your next step · free

Could the Streamlined route fit your facts?

Eight questions on the published gates — the non-residency test, non-willfulness, any examination, which years are open — and a preliminary read on which catch-up path they point at. Free, no account.

Check my catch-up path Check my Streamlined eligibility