Form 14654 is the Certification by U.S. Person Residing in the U.S. that you sign to use the IRS streamlined domestic offshore procedures. In it you certify that you're eligible, that all required FBARs are now filed, that your failure to report foreign income and assets was non-willful, and that your 5% miscellaneous offshore penalty figure is right. Without a complete signed form, your returns are processed the normal way.
This guide follows the IRS pages on the streamlined filing compliance procedures and the domestic and foreign versions, read as of October 2026. It isn't legal advice, and whether your conduct was willful is a question for a professional if you're unsure.
Domestic or foreign: which certification you need
The streamlined procedures come in two versions with two different forms. The foreign version, with its own certification, is for people who meet a non-residency test: in at least one of the last three years with a passed return due date, no US abode and at least 330 full days outside the United States. If you don't meet that test, and for joint filers if either spouse fails it, you're in the domestic version and Form 14654 is yours.
Who can use the domestic version
- You're an individual, or the estate of one. Businesses can't use it.
- You filed a US return, if one was required, for each of the most recent 3 years whose due date has passed.
- You failed to report gross income from a foreign financial asset and pay the tax, and may also have missed FBARs or information returns such as Forms 3520, 3520-A, 5471, 5472, 8938, 926 and 8621.
- The failures were non-willful: negligence, inadvertence, mistake or a good faith misunderstanding of the law.
- The IRS hasn't opened a civil examination of your returns for any year, and you're not under criminal investigation.
- You have a valid taxpayer identification number.
The second point is the big one. The domestic version is for amending returns you already filed. The IRS says you can't use it to file delinquent original returns.
The four statements you're signing
- You're eligible for the streamlined domestic offshore procedures.
- All required FBARs have now been filed.
- Your failure to report all income, pay all tax and submit all required information returns, including FBARs, resulted from non-willful conduct.
- The miscellaneous offshore penalty amount is accurate.
The non-willful statement needs facts behind it, not a one-line denial. You also have to keep the account and asset records that support your penalty figure and be ready to show them if asked.
Working out the 5% penalty
The Title 26 miscellaneous offshore penalty is 5% of the highest aggregate balance or value of the foreign financial assets subject to it. You add up the year-end balances and values of every such asset for each year in the covered period, then take the highest single year.
An asset counts for a year in the 6-year FBAR period if it should have been on an FBAR and wasn't. It counts for a year in the 3-year return period if it should have been on Form 8938 and wasn't, or if it was reported but its income wasn't. Foreign assets can include accounts at foreign banks, accounts at a foreign branch of a US bank, foreign stock held outside an account, and foreign mutual, hedge and private equity funds.
What goes in the envelope
- Amended returns on Form 1040-X for each of the last 3 years, with every missing information return attached.
- "Streamlined Domestic Offshore" written in red at the top of the first page of each amended return and each information return.
- The original signed Form 14654, plus a copy attached to each tax return and information return. Don't attach copies to FBARs.
- Payment of all the tax, the interest on each late amount and the 5% penalty, with your taxpayer identification number on the check.
- If you're asking for late treaty deferral on a foreign retirement or savings plan, the statements the IRS lists for that.
The package goes on paper to the Internal Revenue Service, 3651 South I-H 35, Stop 6063 AUSC, Attn: Streamlined Domestic Offshore, Austin, TX 78741. That address is only for these submissions.
The FBARs are separate
The 6 years of late FBARs don't go in the envelope. You e-file them through the FinCEN BSA E-Filing System, pick Other as the reason for filing late, and type Streamlined Filing Compliance Procedures in the explanation box.
What you get, and what you don't
If you follow the instructions, the 5% penalty replaces accuracy-related penalties, information return penalties and FBAR penalties. That holds even if a return is later picked for audit, unless the exam finds fraud or a willful FBAR violation. The IRS doesn't acknowledge receipt or sign a closing agreement, penalties already assessed aren't refunded, and you'll be expected to file normally from then on. Anyone worried their conduct was willful is pointed to the IRS Criminal Investigation Voluntary Disclosure Practice instead.
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Where submissions go wrong
- Leaving off the red "Streamlined Domestic Offshore" heading. The IRS calls it critical; without it the returns go through normal processing.
- Sending a delinquent original Form 1040. The domestic version only accepts amended returns.
- Skipping an information return because you'd never have attached it to an ordinary 1040. The IRS asks for every required one, even so.
- Forgetting the transition tax. The IRS now says previously unreported income tied to specified foreign corporations has to address section 965 too, if it applies.
- Paying the tax but not the interest on each late amount, which brings a balance due notice later.
The verdict
Form 14654 is a short form with long consequences. Check the foreign version's 330-day test first: its instructions ask for the tax and interest only, with no 5% penalty step, and the IRS says eligible filers won't face failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties. If you're domestic, write a factual non-willful story, calculate the 5% from real year-end figures, and send the whole package together.
Another disclosure rule that trips people up is covered in disclosing a reportable transaction to the IRS.
Frequently asked questions
What is Form 14654?
It's the Certification by U.S. Person Residing in the U.S., the signed statement required to use the IRS streamlined domestic offshore procedures.
What's the penalty under the streamlined domestic procedures?
A miscellaneous offshore penalty of 5% of the highest aggregate year-end balance or value of the foreign financial assets subject to it.
Can I use Form 14654 if I never filed a return?
No. You must have filed a US return, if required, for each of the last 3 years. The domestic procedures can't be used for delinquent original returns.
Where do I send Form 14654?
On paper with the amended returns to the IRS in Austin, TX 78741, Stop 6063 AUSC, Attn: Streamlined Domestic Offshore.
Do I attach Form 14654 to my FBARs?
No. Copies go on each tax return and information return, but not on FBARs, which you e-file separately.
