2026 IRS Streamlined Voluntary Disclosure Programs: Key Considerations for U.S. Taxpayers Living Abroad

U.S. taxpayers living abroad are generally subject to the same filing and payment obligations as those living in the United States. These include, but are not limited to, the obligation to disclose qualifying offshore accounts and other foreign financial assets to the federal government. For taxpayers living abroad who have not met their filing obligations, coming into compliance generally involves utilizing one of the IRS’ streamlined voluntary disclosure programs. Learn more from Maryland international tax attorney Kevin E. Thorn, Managing Partner of U.S. International Tax Advisors:

The IRS Offers Two Streamlined Voluntary Disclosure Programs in 2026

Consistent with prior years, the IRS is offering two streamlined voluntary disclosure programs for U.S. taxpayers living abroad in 2026. Eligible taxpayers can use these programs to come into compliance and mitigate their risk of IRS scrutiny.

1. The IRS’ Streamlined Filing Compliance Procedures

The first of these programs is the IRS’ streamlined filing compliance program. As the IRS explains, submitting a streamlined filing is an option for taxpayers who are prepared to, “certify[] that their failure to report foreign financial assets and pay all tax due in respect of those assets did not result from willful conduct on their part.”

Non-willfulness is a key aspect of streamlined filing eligibility. The IRS independently assesses taxpayers’ certifications of non-willfulness, and if it determines that a taxpayer has submitted a false certification, it can pursue an audit or investigation as warranted. In all cases, taxpayers must be prepared to pay what they owe (including applicable penalties); and, while submitting a streamlined filing provides a way to come into compliance, “the streamlined filing process will not culminate in the signing of a closing agreement with the IRS.” As a result, taxpayers must be confident that submitting a streamlined filing is the best approach under the circumstances at hand.

2. IRS CI’s Voluntary Disclosure Practice

While the IRS’ streamlined filing compliance program provides a means to resolve eligible non-willful tax law violations, IRS CI’s Voluntary Disclosure Practice provides a means for taxpayers to resolve willful violations of the Internal Revenue Code and other applicable laws. As IRS CI explains:

“If you have willfully failed to comply with tax or tax-related obligations, submitting a voluntary disclosure may be a means to resolve your non-compliance and limit exposure to criminal prosecution. . . . A voluntary disclosure will not automatically guarantee immunity from prosecution; however, a voluntary disclosure may result in prosecution not being recommended.”

Submitting a voluntary disclosure is an option for resolving issues related not only to taxpayers’ foreign financial asset disclosure obligations but also to taxpayers’ other filing and payment obligations. Here too, taxpayers must generally be prepared to pay what they owe, though entering into a full-pay installment agreement with the IRS is an option in appropriate circumstances.

Learn More from Maryland International Tax Attorney Kevin E. Thorn

If you would like more information about the options for proactively resolving willful or non-willful federal tax violations in 2026, we invite you to get in touch. To request a confidential consultation with Maryland international tax attorney Kevin E. Thorn, Managing Partner of U.S. International Tax Advisors, please call 240-235-5096 or inquire online today.