Most people who call us about this found out by accident, usually when their bank asked about their US status. If nobody told you Americans abroad still file, the IRS has a program for exactly that. Under the Streamlined Filing Compliance Procedures you file three years of returns and six years of FBARs, and if you live abroad there are no failure-to-file or FBAR penalties at all.
The three most recent years whose due date has passed, as never-filed 1040s or amended 1040-Xs. Each one carries the forms it should have had on time, usually the 2555 exclusion or 1116 credit that takes the US bill to little or nothing.
FinCEN 114s for every foreign account you owned or could sign on, filed electronically. That means pensions, ISAs, TFSAs and the account you closed in 2021, not just the current account.
Form 14653, signed under penalties of perjury. “I didn't know” isn't enough, so we write out when you moved, what you held and how you found out. It's the part the IRS actually reads, and where we spend the most time.
The package is from $1,500 for the three returns and six FBARs. Paper goes in the post to the IRS in Austin, because Streamlined can't be e-filed, and we put the whole mailing together for you.
The foreign track (SFOP) is for people who spent at least 330 full days outside the US, with no US home, in one of the last three years, and whose failure to file was non-willful. If you're living in the US now it's the domestic track and a 5% penalty, so we check your travel dates year by year before anyone accepts that. One thing to know: once the IRS opens an exam on you, Streamlined is gone. On a call we'll confirm which track you're on and exactly which years you'd file, before you commit to anything.