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Many Americans only discover their U.S. filing obligations years after moving to Switzerland. The IRS provides catch-up pathways — most relevant for expats is the Streamlined Foreign Offshore Procedures — designed for taxpayers whose failure to file was non-willful.
What the streamlined path involves
Filing a set number of prior-year tax returns (including any PFIC/Form 8621).
Filing several years of FBARs.
A signed non-willful certification.
"Non-willful" is a legal judgment, and the certification is signed under penalty of perjury. If your facts are near the line, get a professional opinion before filing.
Is it right for you?
The streamlined path is one of several options, and the right one depends on what you missed and why. Atamatax provides preparation support and can help you understand what may apply — this is not legal advice.
IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
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
How many years does streamlined cover?
The foreign offshore procedure involves a set number of years of returns plus several years of FBARs. The exact specifics depend on the program requirements and your facts.
Will I owe penalties?
For eligible non-willful taxpayers, the foreign offshore procedure is designed to avoid certain penalties. Eligibility and outcome depend on your situation.
Do I definitely need streamlined?
Not necessarily — sometimes simply back-filing is enough. It depends on whether you had a filing requirement, unreported income, and foreign accounts. The Tax Risk Check is a good starting point.