Can I just start filing US returns going forward instead of doing Streamlined?

You can file going forward, and nothing stops you amending old returns either. What that route doesn’t do is buy the thing people think it buys. The IRS is explicit that someone who already filed amended or delinquent returns and then uses Streamlined still has to pay penalties already assessed, so a quiet fix first can leave you paying twice for the same years.

What does filing quietly actually get me?

Nothing formal, and that’s the whole point. The named procedures exist because they set out what the IRS will and will not do in exchange for a specific submission. Filing amended returns without entering any of them puts your returns in the ordinary processing stream with no agreed terms attached. The IRS also says plainly that even a proper Streamlined submission carries no immunity, which tells you how little an unstructured filing carries.

“returns submitted under the streamlined procedures may be subject to IRS examination, additional civil penalties, and even criminal liability, if appropriate.” IRS, Streamlined Filing Compliance Procedures

Read that carefully, because it cuts both ways. It’s a caution about Streamlined, and it’s also the answer to anyone who assumes a quiet amendment is safer because it attracts less attention. Streamlined at least comes with published treatment. A quiet filing comes with none, and it’s still a submission the IRS can examine.

Does amending quietly first hurt me if I use Streamlined later?

Yes, in a specific and expensive way. This is the sentence that decides the question and it is stated by the IRS in bold on its own page. Having already filed amended or delinquent returns doesn’t disqualify you from Streamlined, but it doesn’t wipe the slate either. Penalties assessed on those earlier filings stay payable.

“Taxpayers eligible to use streamlined procedures who have previously filed delinquent or amended returns must pay previous penalty assessments.” IRS, Streamlined Filing Compliance Procedures

So the sequence matters. Going quiet first and formal second can produce the worst of both: the penalties from the informal attempt, plus the work of the formal one. Doing it the other way round isn’t available, because you cannot un-file.

Route	What it is	What it gives you
Filing quietly	Amending or filing late with no procedure attached	No published terms, no agreed treatment
Streamlined	A formal submission certifying non-willful conduct	Published treatment, but expressly no immunity from exam or criminal liability
Criminal Investigation Voluntary Disclosure Practice	The route the IRS names for those concerned their conduct was willful	The route to seek assurance on criminal exposure

What if I’m worried my conduct was willful?

Then Streamlined is the wrong door and the IRS says so directly. Streamlined rests on a non-willful certification, and the agency points people with a willfulness concern to a different practice entirely, alongside advice to take professional or legal advice before choosing. That referral is in the IRS’s own words rather than a practitioner gloss.

“Taxpayers who are concerned that their failure to report income, pay tax, and submit required information returns was due to willful conduct and who therefore seek assurance that they will not be subject to criminal liability and/or substantial monetary penalties should consider participating in the IRS Criminal Investigation Voluntary Disclosure Practice and should consult with their professional or legal advisers.” IRS, Streamlined Filing Compliance Procedures

Two eligibility bars matter here and both close doors that quiet filing can trigger. A taxpayer under IRS examination is not eligible for Streamlined, whether or not the examination relates to foreign assets. A taxpayer under criminal investigation is likewise ineligible. Attention you draw with an unexplained amended return is attention that can remove the option you were saving.

What if it’s only FBARs and the income was always reported?

That’s a different and much narrower situation, and there is a route for it. The IRS’s guidance on filing late FBARs now sits on its main FBAR page rather than on the standalone page it used to occupy, under the heading “Filing delinquent FBARs”. The conditions it describes are the familiar ones: the IRS has not contacted you about the late filing, and you are not under civil or criminal investigation.

• What the Streamlined procedure actually costs
• Late FBARs: delinquent filing, amendment, or Streamlined, the triage version of this question
• Where to start if you’re a US citizen in Canada who never filed

One practical note on that move. The standalone delinquent FBAR page no longer resolves, which has been read in places as the IRS withdrawing the procedure. The substance is still published; it moved. Worth knowing before anyone tells you the route is gone.

What should I do next?

Get the facts straight before picking a route, because the routes are chosen on willfulness and on whether you are already under examination, not on price. Write down which years are unfiled, which were amended, and whether any penalty has already been assessed. That list determines which of the three routes is even available to you.

This guide is general information, not tax advice for your specific situation. Which points apply, and how, depends on your facts.