Behind on US taxes from Canada: what catching up involves

You've worked out that you need to file. This page is about the job itself: what's in the package, the order it goes in, what it costs at our published rates, and the parts of it nobody advertises.

The short answer: catching up means three years of US returns with their information returns attached, six years of FBARs and one signed certification, filed together in a specific order. The FBARs are e-filed to FinCEN first, because the certification you sign says they've already been filed. The returns go on paper, to one IRS address in Austin, each marked in red, with the original signed certification. Miss a piece and the IRS processes the returns in the normal course, without the favorable terms.

Landed here earlier in the process, still working out whether you're actually in trouble? Start with the full walk-through for a US citizen in Canada who never filed and come back.

What the work actually is

The Streamlined Filing Compliance Procedures are the IRS's route back into compliance for someone whose failure to file wasn't willful. On the foreign path, the one most Canadians are on, the package the IRS asks for is this:

"U.S. taxpayers (U.S. citizens, lawful permanent residents, and those meeting the substantial presence test of IRC section 7701(b)(3)) eligible to use the Streamlined Foreign Offshore Procedures must (1) 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, file delinquent or amended tax returns, together with all required information returns (e.g., Forms 3520, 5471, and 8938) and (2) for each of the most recent 6 years for which the FBAR due date has passed, file any delinquent FBARs (FinCEN Form 114, previously Form TD F 90-22.1). The full amount of the tax and interest due in connection with these filings must be remitted with the delinquent or amended returns." IRS, U.S. taxpayers residing outside the United States

So there are three moving parts and a fourth that rides along. The returns, three years of them. The FBARs, six years, which is a longer look-back than the returns and surprises most people. The certification, one signed statement on Form 14653. And the information returns that attach to the returns, which for a Canadian file is usually where the work lives: a Form 3520 where a TFSA is in the picture, Form 8938, and a Form 8621 for each Canadian mutual fund or ETF held outside a registered plan.

Each return year also carries its own Form 1116 for the foreign tax credit, which is how the Canadian tax you've already paid gets counted against the US bill. The credit is elective and it's capped by its own limitation, so it's worked out year by year rather than assumed.

One thing worth knowing if you have a Canadian retirement plan you never made a US election for. The IRS says that "For returns filed under these procedures, retroactive relief will be provided for failure to timely elect income deferral on certain retirement and savings plans where deferral is permitted by the applicable treaty. The proper deferral elections with respect to such plans must be made with the submission." That relief exists only if the election goes in with the package, which is a good reason not to file these years as ordinary late returns.

What happens in what order

The sequence isn't obvious and it isn't optional. Half the package is filed electronically to FinCEN and half is mailed on paper to the IRS, and the certification in the middle asserts that the first half is already done.

StepWhat happens
1The account list and the yearsEvery Canadian and other non-US account you held, with the highest balance each one reached in each year. The FBAR test looks at all your foreign accounts added together, at their peak during the year rather than the balance on December 31, so accounts you think of as too small to matter still count. What triggers the filing is the combined total going over US$10,000 at any point in the year, which is a reporting threshold rather than a penalty, and it's a low enough bar that an ordinary chequing and savings pair can clear it. Six FBAR years means the list goes back further than the returns do.
2The taxpayer identification numberEvery return in the package needs a valid one. For a US citizen that's a Social Security number. If you've never had one, this is the item that sets the schedule, so it gets settled first rather than discovered halfway through.
3The returns get preparedThree years, delinquent or amended, with the information returns attached to them and the foreign tax credit worked out for each year. Any treaty deferral election has to be made with this submission, so it's decided here and not later.
4The FBARs are e-filed at FinCENSix years, through the BSA E-Filing System, separately from the returns. The IRS instruction is specific: "On the cover page of the electronic form, select "Other" as the reason for filing late. An explanation box will appear. In the explanation box, enter "Streamlined Filing Compliance Procedures.""
5The certification is signedForm 14653 certifies three things: that you're eligible for the procedures, "that all required FBARs have now been filed", and that the failures were non-willful. Because of that middle clause, step 4 has to be finished before this can be signed truthfully. You submit the original signed statement and attach copies to each tax return and information return, and not to the FBARs.
6The paper package is mailedThe returns can't be e-filed. They go on paper, with "Streamlined Foreign Offshore" written in red at the top of the first page of each return and each information return, the original certification, and the payment for the full tax and interest, to a single address: Internal Revenue Service, 3651 South I-H 35, Stop 6063 AUSC, Attn: Streamlined Foreign Offshore, Austin, TX 78741. That address is single-use. The IRS notes it "may only be used for returns filed under these procedures. For all future filings, you must file according to regular filing procedures."

From there you file normally, on the ordinary schedule, at the ordinary address.

The reason the order matters this much is that there's no gate to fail. The IRS says that "Failure to follow these instructions or to submit the items described below will result in returns being processed in the normal course without the benefit of the favorable terms of these procedures." Nothing bounces back. The returns go through as ordinary late returns and you find out later, or you don't find out at all.

What it costs

Streamlined files for a Canadian usually cost US$2,500 to $4,500 in preparer fees. Here's how that breaks down at our published rates, and what pushes a file to one end of it.

Where everyone starts

$249 flat

About $349 CAD. 60 minutes with a dual-licensed CPA plus a written summary of your file: what you owe where, what needs filing, and your exact quote. Credits in full toward any engagement. Non-refundable.

The catch-up package

from $2,495

The from-$2,495 base fits the foreign-path (SFOP) file with ordinary accounts; TFSAs, Canadian mutual funds, rental years, or the domestic (SDOP) path raise it, and complex catch-ups have run near $5,000.

A starting point, not a quote. Your exact fee is fixed in writing at the assessment.

The years after

from $1,495/yr

Annual filing on both sides starts at $1,495 for one person. A spouse's second separate return is typically 50%. A separate decision, made after the catch-up is done.

A starting point, not a quote. Your exact fee is fixed in writing at the assessment.

The full component-by-component breakdown, including what other firms charge, lives on the guide: what a streamlined package costs for a Canadian. Everything we charge across all our services is on our published cross-border fee card.

What moves the number

It's almost never the income. It's the accounts, and how many forms they drag in.

Pushes it up

  • A TFSA, which raises a Form 3520 position question: memo from $350. Background: whether your TFSA needs Form 3520, and what TFSA reporting typically adds to a return.
  • Canadian mutual funds or ETFs held outside a registered plan. Form 8621 runs from $400 per fund per year at our published rates, and it repeats in every return year. Background: whether your Canadian funds are PFICs.
  • A drawer full of accounts rather than a handful, across six FBAR years
  • Rental income, self-employment, or a corporation anywhere in the picture
  • State returns on top of the federal ones
  • The domestic path instead of the foreign one

Keeps it down

  • Salary income only, T4 or W-2
  • Investments held inside RRSPs and other registered plans
  • A few accounts, and statements you can actually lay hands on
  • One province, no US state filing obligation
  • An account list that's complete the first time, so the six FBAR years don't get rebuilt twice
  • Coming in before deadlines instead of after them

Start with the $249 assessment

Who this is for, and who it isn't

It's for a US citizen or green card holder living in Canada who's behind on US returns and FBARs, where the failure came from not knowing rather than from a decision. Which of the two streamlined routes applies turns on a non-residency test, and the version for citizens and green card holders is about where you actually lived rather than where you're from. If you're not sure which path applies to you, work out which catch-up path is yours before you spend anything.

A few situations we route elsewhere, including away from us.

If you're worried the failure was willful

This isn't your route, and we don't take those files. The IRS points that reader somewhere specific: taxpayers concerned their failure "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."

Nothing here takes the streamlined procedures off the table. That is not the same as being non-willful. Non-willfulness is something you declare yourself on Form 14653, under penalties of perjury, and it is the single thing in a streamlined package worth getting a professional read on before you sign.

If the IRS has already made contact

The door closes. In the IRS's words: "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. Taxpayers under examination may consult with their agent. Similarly, a taxpayer under criminal investigation by IRS Criminal Investigation is also ineligible to use the streamlined procedures."

Note that it says any taxable year, and that it doesn't have to be about foreign accounts. What counts as an examination for this purpose isn't defined anywhere the IRS publishes, so a letter you can't classify is a conversation rather than a self-diagnosis.

If you live in the United States

You're on the domestic route rather than the foreign one, and it carries a penalty the foreign route doesn't, so the cost of the job is different. And if you live in the US and never filed at all, the published criteria don't put you cleanly on either streamlined route. The IRS doesn't publish what that person should do instead. That's a real gap rather than something we're withholding, and it's worth a conversation before anything gets filed.

If it's smaller than a full catch-up

If your income was reported and paid on properly and only the FBARs are missing, that's a different and much smaller job: if the FBARs are the only thing missing.

If the returns are all filed and the gap is a single information return, the IRS runs a separate route for that, filed through normal procedures. It isn't penalty-free, and the IRS says plainly that "Penalties may be assessed in accordance with existing procedures." Either way, you don't need a streamlined package for it.

The honest limits

Six things about this that other catch-up pages leave out.

  1. The IRS never writes back. Returns filed this way "will be processed like any other return submitted to the IRS. Consequently, receipt of the returns will not be acknowledged by the IRS and the streamlined filing process will not culminate in the signing of a closing agreement with the IRS." There is no approval, no certificate, no closing event. Silence is what success looks like.
  2. It isn't an audit shield. Streamlined returns "will not be subject to IRS audit automatically, but they may be selected for audit under the existing audit selection processes applicable to any U. S. tax return and may also be subject to verification procedures in that the accuracy and completeness of submissions may be checked against information received from banks, financial advisors, and other sources."
  3. You still owe the tax and the interest. The full amount of tax and interest due has to be remitted with the returns. The relief runs to penalties and stops there.
  4. Anything already assessed stays assessed. If you filed a couple of years on your own before this, you can still use the procedures, but "any penalty assessments previously made with respect to those filing will not be abated."
  5. The relief is conditional twice over, and it's forfeitable. The IRS sentence, whole: "A taxpayer who is eligible to use these Streamlined Foreign Offshore Procedures and who complies with all of the instructions outlined below will not be subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties, or FBAR penalties." Eligible, and instruction-compliant. It also doesn't survive a later determination that the original noncompliance was fraudulent or that an FBAR violation was willful.
  6. These procedures are administrative, and they get withdrawn. Until recently the IRS also published Delinquent FBAR Submission Procedures, carrying a stated no-penalty position for people whose only gap was the FBARs. That page now returns a 404, and the IRS's own list of compliance options no longer includes it. We're not predicting anything about the streamlined procedures. We're saying that a neighbouring one disappeared inside the last six weeks, which is a fact about how these things work.

Sources for the above: IRS, Streamlined filing compliance procedures; U.S. taxpayers residing outside the United States; Options available for U.S. taxpayers with undisclosed foreign financial assets; Delinquent international information return submission procedures. The withdrawn page is cited from an archived capture dated 2026-06-23, which is an archive and not a live IRS page.

What we need from you to start

Three things, and the first one is most of it. A list of every non-US financial account you've held, with the highest balance each reached in each year, going back far enough to cover six FBAR years. Which years you did and didn't file. And whether you have a valid Social Security number or ITIN, because every return in the package needs one.

That's enough to price the job and to tell you which route you're on. Statements, slips and the rest come after.

Your number comes from the $249 assessment

The range on this page gets you in the right neighborhood. It can't price your file, because nobody can price a file they haven't seen, and the thing that sets the price is your account list rather than your income.

So the entry point is a fixed $249: an hour with a CPA licensed on both sides of the border, then a written summary with your filing list and a firm quote. If you engage us, the $249 comes off the bill in full. If you take the summary and file elsewhere or on your own, that's a fine outcome too.

Start with the $249 assessment

Questions people actually ask

Do I have to pay the back taxes too, or just file?

Both. The IRS is explicit that "The full amount of the tax and interest due in connection with these filings must be remitted with the delinquent or amended returns." The relief a streamlined filing offers reaches penalties, and it doesn't reach the tax or the statutory interest. In practice the tax line is often smaller than people brace for, because Canadian tax already paid usually runs through the foreign tax credit on Form 1116. A typical employee file owes $0 US tax. That's our observation from the files we price, not a rule, and the credit is elective and capped by its own limitation, so it has to be worked out on your numbers rather than assumed.

How far back does this go?

Three years of returns and six years of FBARs. The IRS words it as the most recent three years for which the US tax return due date, or a properly applied for extended due date, has passed, and the most recent six years for which the FBAR due date has passed. The window rolls with the filing season, so it isn't a fixed set of calendar years and we won't name years here.

How will I know the IRS accepted it?

You won't get a letter saying so. The IRS says that returns submitted under either streamlined route "will be processed like any other return submitted to the IRS. Consequently, receipt of the returns will not be acknowledged by the IRS and the streamlined filing process will not culminate in the signing of a closing agreement with the IRS." There is no approval event. Silence is the normal outcome, which is uncomfortable and worth knowing before you start rather than after.

I already quietly filed a couple of years myself. Have I ruined it?

No. The IRS addresses this directly: taxpayers who previously filed delinquent or amended returns on their own "may still use the streamlined procedures by following the instructions set forth below. However, any penalty assessments previously made with respect to those filing will not be abated." So earlier filings don't lock you out, and anything already assessed against those years stays assessed.

I was born in the US and have never had a Social Security number. Does that stop me?

Not necessarily, but it's the first thing to sort out. Every return filed under these procedures has to carry a valid taxpayer identification number, and for a US citizen that's a Social Security number. Someone who isn't eligible for one but has no ITIN can submit under the procedures if a complete ITIN application goes in with the package. How long the underlying number takes to obtain isn't something the IRS publishes, so we plan the timing around it rather than guess at it.

Can I just do this myself?

People do. The sequence is public and it's on this page. The part that catches people out is that half the package is e-filed to FinCEN and half is mailed on paper to a single IRS address, the certification you sign says the FBARs are already filed, and each return has to be marked in red. The failure mode isn't a rejection letter. The IRS says that failing to follow the instructions "will result in returns being processed in the normal course without the benefit of the favorable terms of these procedures." Nothing tells you that happened. You just don't get the terms.

Is this a one-time thing, or am I signing up for something?

The catch-up itself is one job with an end. The obligation isn't. The IRS puts it plainly: after completing the procedures a taxpayer "will be expected to comply with U.S. law for all future years and file returns according to regular filing procedures." You can do those years yourself, take them elsewhere, or hand them to us. Annual filing on both sides starts at $1,495 for one person, and it's a separate decision you make after the catch-up is done.

What if my situation is worse than "I didn't know"?

Then this isn't your route and we're not the right firm for it. The IRS points that reader somewhere specific: taxpayers concerned their failure "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." Nothing here takes the streamlined procedures off the table. That is not the same as being non-willful. Non-willfulness is something you declare yourself on Form 14653, under penalties of perjury, and it is the single thing in a streamlined package worth getting a professional read on before you sign.

Email me the catch-up checklist

The six-step sequence on this page, plus the account list we'd ask you to build, in one page you can work through at your own pace.

About these numbers: prices are in US dollars. Every figure except the $249 assessment is a starting point rather than a quote, and your exact fee is fixed in writing at the assessment. Fees shown are our preparation fees and don't include any tax or interest you may owe. This page is general information about a US filing procedure and about our pricing, not tax advice for your situation, and no outcome with the IRS or CRA is promised. It covers the US side only: Canadian arrears, T1135 reporting and the CRA's Voluntary Disclosures Program are separate questions and nothing here says anything about them.

Ready to find out what your file actually looks like?

One fixed $249, one hour with a dual-licensed CPA, one written summary with your filing list and a firm quote. Credited in full if you go ahead.

Start with the $249 assessment