Our service combines the expertise of CPAs focused on international tax with a structured process designed to remove uncertainty. We do far more than “fill in forms”: we identify the root cause of the noncompliance, rebuild the audit trail for your foreign assets and accounts, and position you on solid ground in front of the IRS.
At the end of the engagement, you receive a complete file that includes all amended or delinquent tax returns, properly filed FBARs, the signed non-willful certification submitted to the IRS, and a technical summary of the case—useful for banks, advisers, or any future audit.
Eligibility assessment
We determine whether you qualify for Streamlined Foreign Offshore Procedures or Streamlined Domestic Offshore Procedures, based on your residency, filing history, and whether your conduct meets the IRS standard of non-willfulness. We can assess whether or not to apply for authorization from the IRS in advance.
Amended tax returns
We prepare up to three years of amended returns, incorporating all previously omitted foreign income and assets, and computing the correct tax, interest, and any reduced penalties that may apply.
FBAR and FATCA reporting
We prepare and file up to six years of FBARs and ensure consistency with FATCA forms and your tax returns, so that the entire package is coherent for both the IRS and FinCEN.
Non-willful certification
We draft and refine the narrative for Form 14653 or Form 14654, the critical certification in which you explain the facts and confirm that your noncompliance was non-willful—rooted in ignorance, error, or poor advice, not in deliberate concealment.
Penalty mitigation strategies
We analyze the IRS streamlined rules and other guidance to use all available mechanisms to eliminate or reduce penalties, avoiding outcomes that are disproportionate to the taxpayer’s situation and risk profile.
Final review and technical file
We provide a complete support package for your records, including copies of everything filed, key calculations, and forward-looking recommendations, so that any future scrutiny can be addressed calmly and efficiently.
Many taxpayers discover that, without realizing it, they failed to file required tax returns or foreign account reports (FBAR, FATCA, or foreign income). Instead of facing severe penalties, the Streamlined Filing Compliance Procedures allow eligible non-willful taxpayers to correct those failures, provided the noncompliance was non-willful and there is no ongoing IRS examination.
We begin with a detailed diagnostic of your situation: which years need to be corrected, the nature of your foreign income, which assets are reportable, and whether you may qualify for the Streamlined Foreign Offshore Procedures or the Streamlined Domestic Offshore Procedures.
The Streamlined Filing Compliance program is designed for individuals and families with foreign assets or income who failed to meet their U.S. tax obligations non-willfully.
Typical profiles include: U.S. citizens or residents living abroad, expatriates with foreign accounts or investments, professionals with global portfolios who were unaware of U.S. reporting rules, and executives with multi-country compensation packages.
It is also valuable for dual citizens who wish to regularize their status without exposing themselves to harsh penalties. Our team works with each client under strict confidentiality, designing a clear and safe path to full compliance.
Frequently Asked Questions
What exactly is the IRS streamlined program?
It is a set of procedures that allow non-willful taxpayers to bring their U.S. tax returns and foreign account reporting into compliance by filing corrected returns and FBARs under a significantly reduced penalty framework (and, in some foreign cases, without FBAR penalties).
How many years do I need to file?
In general, the streamlined program requires three years of tax returns (original or amended) and six years of FBARs. However, every case is evaluated individually in light of the taxpayer’s history and facts.
What does “non-willful” mean?
The IRS treats conduct as non-willful when the taxpayer’s failure resulted from ignorance of the rules, mistake, or poor advice—and not from an intent to hide assets or evade tax. The Form 14653/14654 narrative must clearly support that position.
What is the difference between the Foreign and Domestic procedures?
The distinction depends on whether you meet the IRS criteria for residing outside the U.S. when you enter the program. Foreign Offshore and Domestic Offshore procedures have different rules for penalties and documentation.
What if I am already under audit?
If you are under an active IRS examination or have already received certain notices, the streamlined program is not available. In that situation, we consider other options, such as the IRS Voluntary Disclosure practice or alternative resolution strategies, and depending on the level of risk involved, we can bring in to the process attorneys specializing in tax-related criminal matters.
Resolve your IRS exposure—without panic or disproportionate penalties
If you have unreported foreign income or assets, you may still be able to fix the situation without destroying your finances or your peace of mind. With the right guidance, the process is confidential, technical, and definitive. Schedule an initial evaluation with our specialized team and take the first step toward regaining control and certainty over your U.S. tax situation.
Guillen Pujol CPA P.A
6161 Waterford District Dr., Suite 475 Miami, FL 33126
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Guillen Pujol CPA P.A
6161 Waterford District Dr., Suite 475 Miami, FL 33126
Guillen Pujol CPA P.A
6161 Blue Lagoon Dr.Ste 475, Miami, FL 33126
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