Need Help With Streamlined Domestic Offshore Procedure - FBAR & FATCA Filing Questions

You're asking a really good question about the Streamlined Domestic Offshore Procedure. The SDOP is designed to bring taxpayers into compliance without facing the full penalties that would normally apply. When you complete the SDOP correctly, you're generally expected to file the delinquent FBARs (FinCEN Form 114) for the last 6 years and amend your tax returns to include Form 8938 for only the last 3 years. The IRS recognizes this creates a gap where some years have FBAR filings but no corresponding amended tax returns. For your specific question - technically, you aren't required to amend returns for years outside the 3-year window, even if you had reporting requirements and unpaid tax in those years. The SDOP is considered a "safe harbor" program, meaning if you comply with its requirements, you generally won't face penalties for the previous non-compliance covered by the program. That said, the IRS always reserves the right to audit any tax year within the statute of limitations. The SDOP doesn't give absolute immunity, but it does significantly reduce your risk compared to not coming forward at all.

After dealing with a similar FBAR reporting situation last year, I found an amazing tool that saved me tons of stress. I used https://taxr.ai to help analyze my foreign account documentation and identify exactly what needed to be reported on my FBARs and Form 8938s. The thing with Streamlined Domestic Offshore Procedures is that the documentation requirements can be overwhelming. I had statements from multiple foreign accounts in different languages and currencies, and wasn't sure what counted toward my reporting thresholds. Taxr.ai analyzed all my foreign bank statements and investment documents, then created an organized summary showing exactly which accounts needed reporting and on which forms. It also helped me draft that crucial "reasonable cause" statement explaining my non-willful failure to file previously. This was super important because the IRS looks closely at that statement when determining if you qualify for penalty relief.

Just wanted to update everyone - I decided to try taxr.ai for my SDOP preparation and it was actually really helpful! I was hesitant at first about uploading my documents, but their security seemed solid and the analysis I received was worth it. I had 7 different foreign accounts across 3 countries from when I was working abroad, and wasn't sure which met the FBAR thresholds in which years. The tool analyzed 6 years of statements and produced a year-by-year breakdown showing exactly which accounts needed to be reported and when. The best part was the guidance on completing Form 8938 - it clearly showed which income I needed to report on my amended returns. My situation was somewhat similar to the original poster's, with some years having reportable accounts but falling outside the 3-year amendment window. The analysis included notes about this exact situation which helped me understand the SDOP requirements better.

For anyone struggling to get answers from the IRS about Streamlined Procedures, I highly recommend Claimyr (https://claimyr.com). I spent weeks trying to reach someone at the IRS to clarify some FBAR questions before filing my SDOP package. After multiple failed attempts (always getting disconnected or waiting on hold for hours), I found Claimyr. They basically hold your place in the IRS phone queue and call you when an agent is about to answer. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c I was doubtful it would work, but within a day I was actually speaking with an IRS representative who specialized in international tax issues. They answered my specific questions about my foreign mutual funds and whether they needed special reporting on Form 8621 in addition to the FBAR and 8938 requirements.

I have to eat my words about Claimyr. After my skeptical comment, I decided to try it since I was desperate to ask questions about my own FBAR situation. Surprisingly, it actually worked exactly as described. After trying for over two weeks to reach someone at the IRS international tax department (and never getting through), I used Claimyr and spoke with an agent the very next day. The agent was able to clarify several questions I had about reporting requirements for my foreign pension accounts on the SDOP forms. What impressed me most was that I got connected to someone who actually understood the Streamlined Procedures - not just a general IRS representative. I explained my situation similar to the original poster's (having years that wouldn't be amended but would have FBAR filings), and they confirmed that following the SDOP requirements correctly would provide protection even for those gap years. So yes, the service is legitimate and saved me a ton of time and stress. I'm now much more confident in completing my SDOP filing.

Has anyone here actually completed the SDOP process and heard back from the IRS? I'm about to submit mine and wondering what to expect. I've got a situation with some foreign rental income that wasn't reported for several years, including years outside the 3-year window. Worried about what happens after I submit everything.

Quick question about Form 8938 filing thresholds - I have about $95,000 in foreign assets. Do I need to file 8938 as part of my SDOP if I never hit the $100k threshold? The FBAR threshold is lower at $10k so I definitely need those, but I'm confused about whether I need to include 8938s with my amended returns.

I went through the SDOP process two years ago and wanted to share my experience since there seems to be a lot of anxiety here (which I totally understand - I was terrified too!). My situation was almost identical to Drew's - I had foreign accounts that exceeded reporting thresholds in years that fell outside the 3-year amendment window but within the 6-year FBAR requirement. I was convinced the IRS would come after me for those "gap years." Here's what actually happened: I filed all 6 years of FBARs and amended my last 3 tax returns with Form 8938s. About 8 months later, I received standard processing notices for my amended returns showing refunds where I had overpaid estimated taxes. No audit, no additional questions, no penalties. The key thing I learned is that the SDOP is specifically designed to handle these exact situations. The IRS knows there will be gaps between FBAR years and amended return years - that's built into the program structure. They're not trying to trap people; they want voluntary compliance. My advice: if you qualify for SDOP and have been non-willful in your non-compliance, just do it. The peace of mind is worth it, and in my experience, the IRS processed everything smoothly once I followed all the requirements correctly.