IRS streamlined filing experts are the professionals who prepare submissions under the IRS Streamlined Filing Compliance Procedures — three years of amended or delinquent returns, six years of FBARs, and a certification of non-wilful conduct signed under penalties of perjury. Choose well and the programme wipes out penalties that could otherwise reach six figures. Choose badly and you can convert a fixable oversight into a sworn statement that undermines you in any later examination.
The market for this work ranges from genuine cross-border specialists to volume shops that bolt a template certification onto three hastily prepared returns. Because every firm's website says "streamlined experts", the only reliable filter is the questions you ask before engaging. Here are the twelve we would put to any firm — with the answers that should reassure you and the ones that should end the meeting.
Why IRS streamlined filing experts matter more than any other adviser you will hire
A streamlined submission is unusual in three ways. It is retrospective — the facts are fixed, and the craft lies in presenting them accurately and completely. It is sworn — the Form 14653 certification is signed under penalties of perjury, so an exaggerated or careless narrative is not marketing, it is exposure. And it is effectively one-shot: there is no formal acceptance letter, submissions can be selected for review, and amending a streamlined filing after the fact invites exactly the scrutiny the programme exists to avoid.
The IRS has also never promised the programme is permanent — the streamlined procedures page notes it may be closed or changed at any time. That combination — sworn, one-shot, time-limited — is why the vetting below is worth an hour of anyone's life. Most people making this decision are doing it once, under stress, after a bank letter or a FATCA notice, with no way to benchmark the advice they are being given. The twelve questions that follow are that benchmark: they are the ones a competent rival firm would ask about your submission if it ever had to defend it.
1. How many streamlined submissions have you actually filed?
Not "do you offer it" — how many, and how recently. The procedures have technical corners (the non-residency test, PFIC computations, treaty-based pension positions) that only repetition teaches. A credible specialist will give you a number in the dozens or hundreds and can describe how submissions have been reviewed in practice. Be wary of any firm that answers with its years of general experience rather than its streamlined count — a thirty-year domestic CPA practice can still be on its third submission.
2. Who determines whether I am actually non-wilful — and what if I am not?
The programme is only available for non-wilful conduct: negligence, inadvertence, mistake, or a good-faith misunderstanding of the law. A serious firm interrogates your facts before recommending the route — when you learned of your obligations, what advice you received, how your accounts were used — because recommending streamlined to a wilful taxpayer is the most dangerous advice in this field. If a firm quotes you a streamlined fee before asking a single question about your knowledge and conduct, it is selling a product, not exercising judgement. The right answer includes a described process, and a referral path to a tax attorney if wilfulness is even arguable.
3. Foreign or domestic procedures — and can you show the residency computation?
The difference is worth 5% of your highest offshore balance. The foreign procedures (SFOP) carry no penalty at all; the domestic procedures (SDOP) impose a 5% miscellaneous offshore penalty on the highest aggregate year-end value of the relevant assets. Eligibility for SFOP turns on a precise non-residency test — for citizens, at least one of the three years with no US abode and 330 full days physically outside the US. A specialist should compute your day counts before quoting, not assume. Our comparison of the streamlined domestic and foreign offshore procedures sets out how much turns on this single determination.
4. Who writes the Form 14653 narrative, and will I see the strategy behind it?
The certification narrative is the heart of the submission — it must explain the full story of your non-compliance: how the accounts arose, why the filings were missed, when and how you discovered the obligation. Ask who drafts it (a senior professional or a paralegal with a template), how many drafts you will review, and how the firm handles unhelpful facts. The wrong answers are a bare template — IRS guidance is explicit that conclusory statements are insufficient — and equally a novel of over-explanation that volunteers arguments a reviewer never asked for. You are entitled to understand every sentence you are about to swear to.
5. Exactly which years and forms are included in your fee?
The correct scope is three years of tax returns, six years of FBARs, and every information return those years require — Forms 8938, 5471, 8621, 3520 as your facts demand. The classic bait-and-switch is a headline fee covering three "simple" 1040s, with each PFIC computation and each Form 5471 billed as a surprise extra at hourly rates. Insist on a written scope listing form numbers, and read our breakdown of what streamlined filing actually costs before comparing quotes — the cheapest and most expensive quotes are usually mispriced in opposite directions.
6. How do you handle PFICs, pensions and the other cross-border landmines?
For an American in the UK, the three back-year returns are not ordinary returns. ISAs and UK funds are typically PFICs requiring Form 8621 computations; UK pensions need treaty positions taken deliberately; UK tax paid needs foreign tax credit engineering so the catch-up years generate little or no US tax — you can preview that mechanic with our foreign tax credit calculator. Ask the firm to walk you through how it treats an ISA, a SIPP and a UK limited company shareholding. A firm that has no ready answer will learn on your file, at your risk.
7. Who signs my returns, and who represents me if the IRS asks questions?
Ask for the name and credential of the person signing as preparer — attorney, CPA or Enrolled Agent, the three credentials with unlimited practice rights before the IRS — and confirm that post-submission questions are handled by the same team under the same engagement. Some volume shops outsource preparation and vanish after filing; the moment a follow-up letter arrives you become a new client of whoever will take you. At TaxStone the Enrolled Agents who prepare a streamlined submission are the same people who answer for it afterwards, and we regard that as the minimum standard, not a selling point.
8. What is your position if my submission is selected for review?
Streamlined submissions are processed without an acceptance letter, and a subset are examined. A serious firm can tell you: how often its submissions have been questioned, what the questions concerned, how the matters resolved, and what its representation arrangements and fees are for that scenario. A firm that says "that never happens" is telling you it has either filed very few submissions or is not paying attention to the ones it filed.
9. Will you quantify my exposure under the alternatives before I choose?
Streamlined is one of several doors. Depending on your facts, the delinquent FBAR submission procedures or delinquent international information return procedures may resolve everything with no penalty and no sworn narrative — or, at the other extreme, a wilfulness problem may point to the attorney-led voluntary disclosure practice instead. A genuine expert presents the options with numbers attached: tax, penalty and risk under each route. If the only tool a firm sells is streamlined, every client looks like a streamlined case.
10. How will you keep me compliant after the catch-up?
A streamlined submission certifies, in substance, that you have fixed the past and will comply in future. Missing the very next year's return or FBAR is therefore worse than an ordinary lapse — it sits on top of a sworn statement. Ask what the ongoing annual engagement looks like, what it costs, and how the firm transitions you from catch-up to routine filing. A firm with no ongoing service is structurally incentivised to treat you as a transaction; the firm handling your future filings has its own name attached to the certification's promise.
11. Who does the work — and who else sees my data?
Six years of complete financial records is the most sensitive file most people will ever hand to anyone. Ask where the work is performed, whether any of it is subcontracted or sent to an offshore processing centre, how documents are transmitted and stored, and who in the firm can access them. None of these questions has a single right answer, but a firm that cannot answer them crisply has not thought about the question — and this is not a file on which to discover that.
12. Why are you quoting that price?
Fees for competent streamlined work vary widely with complexity — account count, PFIC exposure, entities, trusts. What should not vary is the firm's ability to explain its number: which forms, which years, which computations, what is excluded. A quote far below market usually means template narratives and missing information returns; far above market, with heavy attorney involvement for an obviously non-wilful case, can be equally poor value. The explanation, not the amount, is the diagnostic.
How to run the process — and what to do next
Speak to two or three firms, put the twelve questions to each, and insist on written scope before paying anything. Then move: the streamlined procedures have outlived many predictions, but the IRS states plainly that the programme can change or close at any time, and eligibility ends the moment the IRS contacts you first about the missed years. Every month of delay is a month in which a FATCA data feed, a bank letter or a routine notice can take the best route off the table.
If you would like TaxStone to be one of the firms you interview, we will answer all twelve questions in writing before you commit — contact us or book a free consultation and bring your account list and your dates.
