# Streamlined Update



## islander_expat

So my documents were finally submitted for the streamlined process in January by my attorney. 3 years of income tax returns, 6 years of FBARs and the questionnaire. At the end of February my attorney said that it shows on the system that the IRS has processed the returns, but we can't say that we've been 100% successful until the IRS issues a letter stating that they're taking no further action.

Does anyone know how long they take to process and issue this letter? My Lawyer says that it could be anywhere from 2 months to 6 months.


And is it a good sign that they've processed the returns? I am categorized as low-risk by my attorney (under the FEIE, no dependents, no retirement or pension, i'm only 28, no refunds, very little unearned income)


----------



## BBCWatcher

Reportedly they may not even issue a letter. Yes, it's a good sign you're "in the system."

If you don't hear anything after, say, 6 months you can order a tax transcript from the IRS if you like. That's hard proof of filing. (And that'll probably pick up your 2013 filings, too, assuming you wait a little bit after you send that one in.)

The IRS always reserves the right to send you a letter, even sometime later. There's nothing special about that whether you're filing just this year's forms or several years. Don't lose sleep over this.


----------



## islander_expat

BBCWatcher said:


> Reportedly they may not even issue a letter. Yes, it's a good sign you're "in the system."
> 
> If you don't hear anything after, say, 6 months you can order a tax transcript from the IRS if you like. That's hard proof of filing. (And that'll probably pick up your 2013 filings, too, assuming you wait a little bit after you send that one in.)
> 
> The IRS always reserves the right to send you a letter, even sometime later. There's nothing special about that whether you're filing just this year's forms or several years. Don't lose sleep over this.




Great thanks for this BBC, i can always count on your realistic views.

I'm almost ready to file my 2013 as well, it's a bit of a task in this country for FBAR info, when you go to a bank and say "I need to get the highest balance maintained and the interest paid on all of my accounts" they watch you and wonder what the hell you need that for? They file your request for info as low priority and you have to wait about 2 months for the letters.


----------



## Bevdeforges

islander_expat said:


> Great thanks for this BBC, i can always count on your realistic views.
> 
> I'm almost ready to file my 2013 as well, it's a bit of a task in this country for FBAR info, when you go to a bank and say "I need to get the highest balance maintained and the interest paid on all of my accounts" they watch you and wonder what the hell you need that for? They file your request for info as low priority and you have to wait about 2 months for the letters.


Just a quick tip here - you don't actually need a letter or other confirmation from your bank about the high balances. You can "eyeball it" or even make a decent estimate. If in any doubt, round up - or add a few thousand $$ to your best guess.

They don't really check the actual figure you list, as long as it's reasonable. (OK, report that your high balance was a few hundred million dollars, and maybe they'll follow up - at least to see that you reported the interest paid correctly on your tax returns...)

Basically, there's no penalty for over-reporting. They're mostly interested in the account number and address information.
Cheers,
Bev


----------



## DavidMcKeegan

The thing to remember with the IRS is that "No News is Good News". You may never hear another peep from them...and take that as a good thing!


----------



## Pinay Sunshine

islander_expat said:


> I'm almost ready to file my 2013 as well


Did you not submit the 2013 together with 2010-2012? Does the 2013 get sent to the regular IRS address separately?


----------



## islander_expat

Pinay Sunshine said:


> Did you not submit the 2013 together with 2010-2012? Does the 2013 get sent to the regular IRS address separately?


My streamlined process started in 2013 so the applicable years that I submitted were 2012-2010 and FBARS were 2012-2007. When I made my streamlined submission in January the tax season was not open So I could not file the 2013 with the streamlined package. Lawyer said I will just continue to file the 2013 as a normal person would, so I did.


At the end of February my lawyer said that the streamlined returns were processed, which is why I created this thread to give an update. My case is a bit different though because my tax returns are veery simple; I have no fancy investments, no property in my name, very little unearned income, no eligible dependents, earn under the FEIE limit, only been working for the last 7 years, only 28 yrs old. I can't officially say that I'm out of the woods yet because the irs has not issued me a letter, but the lawyer said that if they wanted to nail me they would have already responded. Regardless of the outcome I'm not going to worry about something that I have no control over. I'll cross that bridge if I have to.

I would however state that I don't mind paying some accountant fees every year to follow the law, a law doesn't become null and void just because I don't agree with it. I am going to continue being compliant for as long as I can...I owe zero tax at the moment and I don't suspect that will change anytime soon. If they remove the FEIE and FTC programs I will of course consider renouncing because I just won't be able to afford it.

As soon as I get any updates I will post it in this thread so that others can have an idea of what's going on. But like I said, my financial life is pretty boring and I don't expect any major issues arising out of the streamlined.

And for those who are wondering what a good night sleep feels like, ask me because I can tell you what that's like now.

Regards,


----------



## islander_expat

UPDATE:
Received an email yesterday from my attorney who informed me that based on the new guidelines for the streamlined filing procedures the IRS will not be issuing me a letter of streamlined compliance and instead they will just process the returns and fbars(as they did back in February) and close out the case with no penalties or fees.

So good news for me so far, the only worry I have going forward is ensuring I keep compliant in the wake of all these ever changing tax laws. I will saw however that my lawyer was excellent throughout the whole thing. She never took advantage of my ignorance or made me paranoid in any way.

The help I got on this forum from Bev and BBC was invaluable. If anyone has questions regarding my experience with this whole thing and how it may be similar to yours please ask and I will try to respond as best as possible. If you want to find out about the firm that I used I will only respond via private message because I don't want to seem like an advertiser.


Regards,


----------



## someNri

Islander_exapt,
Thx for your update. I am a US resident and planning to do the streamlined procedure that is now open for residents too. This is all new to me, hence a few questions.

1. How much ballpark did it cost you in fees (attorney, cpa wise)? Did you delegate the whole work to them or did you do the work and only have them review? 

2. Did you have to submit copied your foreign bank statements etc with the streamlined package? 

3. Prior year Fbars that you filed, did you submit them right after mailing out the streamlined package? 

4. Could you share the name/contact of the attorney you went with?

Thx!


----------



## FilingLate

You can just simply hire a CPA, attorneys are irrelevant now.
Don't know but 3 years of amended return and 6 years of fbar depends on the accountant i would say somewhere around 1k-3k


----------



## the_mighty_tim

For what it's worth, I submitted my streamlined returns back in January, and I've not heard anything.

I like to subscribe to the "no news is good news theory". Helps me sleep better at night (which is something I definitely was not doing when I found out about my tax situation).


----------



## someNri

FilingLate said:


> You can just simply hire a CPA, attorneys are irrelevant now.
> Don't know but 3 years of amended return and 6 years of fbar depends on the accountant i would say somewhere around 1k-3k


Thx. So confusing, I read somewhere that the reasons you provide in the certification should prove non-willfulness etc so it can be drafted by a lay person.


----------



## islander_expat

someNri said:


> Islander_exapt,
> Thx for your update. I am a US resident and planning to do the streamlined procedure that is now open for residents too. This is all new to me, hence a few questions.
> 
> 1. How much ballpark did it cost you in fees (attorney, cpa wise)? Did you delegate the whole work to them or did you do the work and only have them review? Approximately 4000USD, this included all the consultations, the representation fees, and the preparation of your returns/fbars etc...) i supplied the data, they prepared everything, had me review it and then submitted on my behalf (my power of attorney was signed over to them)
> 
> 2. Did you have to submit copied your foreign bank statements etc with the streamlined package? Nope, this is not required, you supply the figures. It's a good idea to have the records in the event that the IRS needs them (which is unlikely) but you don't need to submit them for the streamlined package to the IRS
> 
> 3. Prior year Fbars that you filed, did you submit them right after mailing out the streamlined package? (everything was submitted as one package, three years income tax, 6 years FBARs)
> 
> 4. Could you share the name/contact of the attorney you went with? (yes i can, but only via private message)
> 
> Thx!



See responses above.


----------



## someNri

Islander_exap, Thanks you so much!
For some weird reason, I don't get the option to send a private message. Can you try sending me one?


----------



## DownunderInUS

I agree that only CPAs are the reasonable option at this point with the new 6/18 streamline procedure update. 

I have started talking to a few CPAs, some can still be really expensive, higher than $3K. 
I guess what some posting here is aiming for is finding a referal to a good CPA, but that is only allowed in Private Messages. 

Also, I read that CPAs are state licensed and can only represent you where they are licensed. 
So it is important to deal with one in your state. 

I found another opton - EAs - IRS Enrolled Agents are another option as they are approved on federal level, that they can represent you in case there is an issue with the filing. I'd like to get some feed back if what I learned about EAs is right.


----------



## DownunderInUS

someNri said:


> Islander_exap, Thanks you so much!
> For some weird reason, I don't get the option to send a private message. Can you try sending me one?


When you join this forum, a welcome note says that you have to have at least 5 posts to become an active member to enable you to post Private Messages. 

I have the same issue as I can not find anywhere that allows me to use PMs, being a new member.


----------



## DownunderInUS

DownunderInUS said:


> I agree that only CPAs are the reasonable option at this point with the new 6/18 streamline procedure update.
> 
> I have started talking to a few CPAs, some can still be really expensive, higher than $3K.
> I guess what some posting here is aiming for is finding a referal to a good CPA, but that is only allowed in Private Messages.
> 
> Also, I read that CPAs are state licensed and can only represent you where they are licensed.
> So it is important to deal with one in your state.
> 
> I found another option - EAs - IRS Enrolled Agents are another option as they are approved on federal level, that they can represent you in case there is an issue with the filing. I'd like to get some feed back if what I learned about EAs is right.


This reply was intended to be relate to FilingLate's response on 6/22/14. 

"You can just simply hire a CPA, attorneys are irrelevant now.
Don't know but 3 years of amended return and 6 years of fbar depends on the accountant i would say somewhere around 1k-3k". 

Just learning how to respond properly - and that is with the use of Quote.


----------



## Bevdeforges

DownunderInUS said:


> I found another opton - EAs - IRS Enrolled Agents are another option as they are approved on federal level, that they can represent you in case there is an issue with the filing. I'd like to get some feed back if what I learned about EAs is right.


EAs are an excellent option - and often somewhat cheaper than a CPA. You can find out more about EA's on the website for their professional association: NAEA | Powering America's Tax Experts
Cheers,
Bev


----------



## DownunderInUS

Bevdeforges said:


> EAs are an excellent option - and often somewhat cheaper than a CPA. You can find out more about EA's on the website for their professional association: NAEA | Powering America's Tax Experts
> Cheers,
> Bev


Thanks for confirming. 

I am not able to get a list from NAEA but was able to get one from MSEA which is also affiliated with NAEA. 

Problem is; the list is long and there's no description if they are expat service experts. So I am back to scouring the internet hoping to find some sort of 'list' of expat services that are recommended by real people. But in doing so, I found there are those that are just advertising services. 

Finding a good one is not easy. I wanted to be sure filing is accurate. I am not keen to get the cheapest one - only a good one even if fee is a little more. 
In short, it's like finding a needle in a haystack.


----------



## someNri

DownunderInUS said:


> Also, I read that CPAs are state licensed and can only represent you where they are licensed. So it is important to deal with one in your state.


Ah good point. Also, should one amend state returns to in the streamlined procedure? (I guess yes esp in the case where amending fed results in some being owed to state)


----------



## Bevdeforges

The NAEA site has a "Find an AE" link on the very top line of their home page, where you can get a listing by location. I know they do list "specialties" on the site, though I'm not sure how many list expat assistance. That said, the listings on the site are voluntary and so have no ratings attached.

You can always schedule an interview appointment to meet potentials face to face and grill them a bit about their experience.
Cheers,
Bev


----------



## DownunderInUS

someNri said:


> Ah good point. Also, should one amend state returns to in the streamlined procedure? (I guess yes esp in the case where amending fed results in some being owed to state)


I am not an accountant, but I would assume that anything affecting the taxes you paid at federal level will affect State tax as well. But check with an accountant to be sure.


----------



## DownunderInUS

islander_expat said:


> My streamlined process started in 2013 so the applicable years that I submitted were 2012-2010 and FBARS were 2012-2007. When I made my streamlined submission in January the tax season was not open So I could not file the 2013 with the streamlined package. Lawyer said I will just continue to file the 2013 as a normal person would, so I did.
> 
> At the end of February my lawyer said that the streamlined returns were processed, which is why I created this thread to give an update. ...
> 
> UPDATE:
> Received an email yesterday from my attorney who informed me that based on the new guidelines for the streamlined filing procedures the IRS will not be issuing me a letter of streamlined compliance and instead they will just process the returns and fbars(as they did back in February) and close out the case with no penalties or fees.


@ISLANDER EXPAT - I understand that your case is simple and straightforward. and that you should be right with taxation office by now. Ah, being young has its advantages! And also being an 'islander' too. 

I have some confusion following your thread, can you please enlighten me - 

1) Is your first filing in Jan thru your lawyer made under under Streamline OVDP 2012?
If so, there is a closing letter from tax office expected, but your lawyer said in Feb IRS won't issue you a letter anymore because of the new rule changes. But the new changes did not become public until June 18th this year. 


2) The filing done by your lawyer followed the new rule changes on OVDP 2012 made in June 18 this year. 
IRS made it 'less harsh' for ordinary citizens who are not hiding assets in tax haven countries. One has to back file three years of 1040x, and six years of FBAR. IRS clearly stated that you will not get any letter from them once your application is processed. 
Is your lawyer well aware of the new changes when he filed for you in January? 
Or he filed it that way because your case is simple and does not owe back taxes?

Hope you can clarify. It helps to understand that IRS actually make considerations for ordinary people like you and me.


----------



## islander_expat

DownunderInUS said:


> @ISLANDER EXPAT - I understand that your case is simple and straightforward. and that you should be right with taxation office by now. Ah, being young has its advantages! And also being an 'islander' too.
> 
> I have some confusion following your thread, can you please enlighten me -
> 
> 1) Is your first filing in Jan thru your lawyer made under under Streamline OVDP 2012?
> If so, there is a closing letter from tax office expected, but your lawyer said in Feb IRS won't issue you a letter anymore because of the new rule changes. But the new changes did not become public until June 18th this year.
> 
> The Lawyer told me that I will not be receiving a letter on June 20th, i got a tax transcript in February indicating that the returns and FBARs were processed. So the information came form the lawyer post June 18th
> 
> 
> 2) The filing done by your lawyer followed the new rule changes on OVDP 2012 made in June 18 this year.
> IRS made it 'less harsh' for ordinary citizens who are not hiding assets in tax haven countries. One has to back file three years of 1040x, and six years of FBAR. IRS clearly stated that you will not get any letter from them once your application is processed.
> Is your lawyer well aware of the new changes when he filed for you in January?
> Or he filed it that way because your case is simple and does not owe back taxes?
> 
> My case was filed in January in accordance with the rules of the 2012 Streamlined process (FBARs questionnaire, letter of apology and explanation, 1040s 2555s etc....), was processed in February and we were waiting on the closing letter, I filed my 2013 returns and FBARs on time through the normal process and kept on following up with my lawyer to ensure that i got the streamlined closing letter. On June 20th the Lawyer sent me an update stating that because of the new terms of the streamlined she was informed that no closing letter will be issued and my submission was processed normally
> 
> Hope you can clarify. It helps to understand that IRS actually make considerations for ordinary people like you and me.



See my responses in blue above, please respond if you have any questions.


Regards,


----------



## P123

Hi Islander Expat, I am currently in a similar situation as you were in: I submitted my Streamlined Procedure 8 months ago, April, 2015 (I am a dual citizen--US/Austria) and have been living in Austria for the last 7 years. I have yet to get a response and my CPA also told me that no news is good news, however, he also told me that I can be audited up to 3 years post Streamline submittal.

You mentioned your lawyer told you that you were all in the clear? Does that mean for audit as well, or just the Streamline acceptance? 

Thanks for your help!


----------



## jbr439

No news is good news (why the IRS can't send out a simple notice of assessment is another story). However, if you want verbal assurance, then call (on your own dime) and ask about the status of your returns (that's what I have done in the past). The closer to 11pm you call the less of a wait there is.



> The IRS Office in Philadelphia provides international tax assistance.
> This office is open Monday through Friday from 6:00 a.m. to 11:00 p.m.
> EST and can be contacted by:
> 
> Phone: 1 (267) 941-1000 (not toll-free)


----------



## P123

Thanks Jbr for your reply. Are your sure that if I call up I will be told the statutus of my 1040s as well as my fbars? (Three 1040s and the six Fbars in the streamlined procedure)

Thanks


----------



## jbr439

Philipp123 said:


> Thanks Jbr for your reply. Are your sure that if I call up I will be told the statutus of my 1040s as well as my fbars? (Three 1040s and the six Fbars in the streamlined procedure)
> 
> Thanks


I don't know about FBARs, I've never asked about them. Were copies of the FBARs required to be filed along with the returns? I seem to recall this being the case at one point.

I am 100% sure you'd be told about the status of your 1040s. Like I said, I've done this on several occasions.

FWIW, on every occasion except one, the IRS agents I talked with were pleasant, professional, and helpful.


----------



## BBCWatcher

Alternatively just send IRS Form 4506-T (or 4506T-EZ) to request a tax transcript.


----------

