What does the Streamlined procedure actually cost for a Canadian?

For a Canadian who never filed US returns, the Streamlined Foreign Offshore Procedures usually cost US$2,500 to $4,500 in preparer fees, and the IRS adds no penalty on top. A typical employee file owes $0 US tax. What you’re really paying for is volume and judgment: 3 years of returns, 6 years of FBARs, a certification, and the TFSA, RESP, and mutual-fund calls that decide which end of that range you land on.

What do you actually have to file under the Streamlined Foreign Offshore Procedures?

Three years of returns, six years of FBARs, and one certification. The IRS spells it out on U.S. Taxpayers Residing Outside the United States: returns “for each of the most recent 3 years for which the U.S. tax return due date (or properly applied for extended due date) has passed,” FBARs “for each of the most recent 6 years for which the FBAR due date has passed,” and Form 14653, certifying the failure “resulted from non-willful conduct.”

Eligibility rests on two tests: non-willful conduct, defined by the IRS as “negligence, inadvertence, or mistake,” and the non-residency test, met when in at least one of the three return years you had no US abode and spent at least 330 full days physically outside the US. A dual citizen who’s lived in Canada the whole time passes without trying.

Does the IRS charge a penalty under the foreign version?

No. Under the foreign procedures an eligible filer “will not be subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties, or FBAR penalties” (IRS, U.S. Taxpayers Residing Outside the United States). You pay whatever tax the three returns actually show, and a typical Canadian employee file shows $0.

If you live in the US instead, the streamlined route carries a Title 26 miscellaneous offshore penalty “equal to 5 percent of the highest aggregate balance/value” of your foreign financial assets (IRS, U.S. Taxpayers Residing in the United States).

Route	Who qualifies	What you file	IRS penalty	Why people pick it
Streamlined Foreign Offshore	Non-willful, meets the non-residency test (no US abode, 330+ days outside the US in one of the 3 years)	3 years of returns, 6 years of FBARs, Form 14653	None	The default for Canadians who never filed
Streamlined Domestic Offshore	Non-willful, lives in the US	3 years of returns, 6 years of FBARs, its own certification	5% of the highest aggregate foreign-account balance	US residents who missed the foreign side
Late FBARs on their own	Returns were filed with the income on them; only FBARs missing	The late FBARs, e-filed with an explanation	Possible; the IRS says file “as soon as possible to keep potential penalties to a minimum” (IRS FBAR page)	Nothing else needs fixing
Doing nothing	Nobody, formally	Nothing	Everything streamlined waives stays available	It feels free this year

What makes a Canadian streamlined package cheap or expensive?

Accounts. The returns are the predictable part; the price moves with how many disclosure forms your accounts pull in and how much judgment each needs.

Component of a Canadian file	When it applies	Effort
3 x Form 1040 with Form 1116 foreign tax credits	Every file	Medium; the core of the job
6 x FBAR (FinCEN Form 114)	Aggregate accounts over US$10,000 at any point in the year (nearly everyone)	Light; it’s volume work
Form 8938	Only above the living-abroad thresholds (worked example below)	Light when it applies
TFSA reporting position (Forms 3520 and 3520-A)	Any TFSA	Medium to heavy; a judgment call firms handle differently
RESP	Any RESP	Medium to heavy; the same trust question plus government grants
Canadian mutual funds or ETFs outside registered accounts (PFIC, Form 8621)	Each fund in a non-registered account	Heavy; the single biggest cost multiplier
Self-employment income	Business or freelance years	Heavy; adds schedules to every return

Two files with the same salary can land thousands of dollars apart because one holds three Canadian equity funds in a margin account. A US shareholder of a passive foreign investment company generally files Form 8621 per fund, per year, and those computations are the slowest work in any catch-up file.

What do firms actually charge for streamlined filing?

The generic expat anchors are public. Greenback prices the package at a “flat fee of $1,750” covering 3 years of federal returns and 6 years of FBARs at up to 5 accounts per FBAR (Greenback, streamlined package FAQ). Taxes for Expats lists its CPA-led streamlined package at $1,450, adjusted to $1,650 once income passes $100,000 (Taxes for Expats fee schedule). Fair numbers for a plain file: salary, a bank account or two, no TFSA, no funds.

A Canadian file is rarely that plain. Here’s where ours land:

Why is the Canadian version usually more work than a generic expat file?

Because the standard Canadian savings toolkit is exactly what US disclosure rules fixate on. A TFSA forces a reporting decision: firms split on whether it belongs on Forms 3520 and 3520-A as a foreign trust, and somebody has to take a documented position either way. An RESP raises the same trust question. Canadian mutual funds in an ordinary non-registered account walk straight into the PFIC regime. A generic expat package priced for a salary and a chequing account hasn’t budgeted for any of it.

It’s also where one CPA who owns both sides of a catch-up file earns the fee: the foreign tax credits only reconcile if the Canadian returns are read correctly.

What happens if you just keep not filing?

The discount evaporates the moment the IRS finds you first. “If the IRS has initiated a civil examination of taxpayer’s returns for any taxable year, regardless of whether the examination relates to undisclosed foreign financial assets, the taxpayer will not be eligible to use the streamlined procedures” (IRS, Streamlined filing compliance procedures). At that point the whole waived-penalty list (failure-to-file, failure-to-pay, information returns, FBAR) is back in play, and on FBARs the IRS is blunt: “Filing an FBAR late or not at all is a violation and may subject you to penalties” (IRS FBAR page).

Waiting doesn’t shrink the job either: the package is always the most recent three return years and six FBAR years on the day you file, so next year’s version is the same size.

What should I do next?

Check eligibility honestly first: non-willful conduct plus the 330-day non-residency test covers most Canadian-resident dual citizens who simply didn’t know. Then build the account list before you talk to any firm, every bank, brokerage, TFSA, RRSP, and RESP with rough balances, because that list sets the quote. If you’d rather hand the whole thing off, our US tax catch-up service runs streamlined packages on a flat, quoted fee.

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