# What if I don't file my US tax return?



## bluewormx

Hello everyone,
US citizen moved to UK as 11 month old baby, Grew up in UK, enlisted US marine corps age 19 (1992).

IIRC filled my 1040EZ for fiscal years 1992, 1993, 1994, 1995.

Naturalised Spanish citizen in Spanish consulate Los Angeles CA, Summer 1996.

Honarably discharged from Marine Corps, Nov 1996.


Moved to Spain and have not filed my taxes since, Just learned that I'm supposed to. 

I have been married to a spanish national since 2001, we have 2 kids who are both spanish nationals and cannot opt to direct US citizenship I'm 2 weeks short of the 5 years neccessary. I was really dissapointed on hearing this, I considered it my gift to them. On learning of my and their possible future tax obligations the gift would have been a poisoned apple.

My wife and I are married under communal gains, in other words everything half each.
My wife is a civil servant and I am a simple mechanic, we own a small apartment and are paying a mortgage.
I have not been to the USA since my discharge from the service 17 years ago, and have no plans to in the future, I have no close relatives in the US, or nothing.

There is no way I owe the IRS anything. Ethically there is no way I am disclosing my wife's personal info with them. We have 2 joint accounts FATCA would violate her Data protection rights

The options I am pondering:

1. Do nothing, not file see what happens. There is no way I'm going to get compliant without expert help, besides I refuse to deal with it every year.

2. Renounce US citizenship.
I would still need expert help to do exit tax thing.

What are everyones views. Thanks in advance.


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## BBCWatcher

The G20 just agreed to start _automatic_ tax data sharing within the next couple years, and that could be "interesting" let's say. I don't think we know yet what data will be shared and how it'll be used, but the whole point is to reduce tax evasion. You're probably right that you wouldn't owe any U.S. taxes (based on your general description), and, if so, it's unlikely the IRS will conclude otherwise even with data about you. But there is that pesky FBAR business which doesn't require a tax liability. Who knows if the U.S. will start to go after those relatively easy FBAR penalties.

What makes you think you need expert help, particularly in this age of TurboTax, TaxAct (even the free one), etc? You managed multiple years of 1040EZs, so you've got some good experience. Take a look at the IRS's streamlined compliance program (and maybe the free TaxAct to run a current draft filing) and see what you think.

It's very unlikely you would have to file FATCA reports from your general description. FBARs, maybe. Sorry, data protection doesn't apply for at least two reasons. One is because the U.S. limits its inquiries only to your accounts and your personal scope of knowledge. They're asking your wife nothing, and her actual secrets remain her secrets. The fact your accounts happen to have a joint signer doesn't matter -- they're still your accounts. Moreover, the EU Data Protection Directive explicitly allows tax authorities to collect your data, i.e. to do their jobs. FBAR is well within those bounds. If you think FBAR is invasive, take a look at Italy's Form RW some rainy day -- and that's an EU country. If FBAR is a bathroom scale, Form RW is like that movie in which a miniaturized crewed submarine swims around inside your body for several hours.


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## bluewormx

The whole nature of tax sharing sends a chill down my spine, it is so Orwellian.
I really need to find my tin foil hat.

Thanks for your reply BBCwatcher, do you have any insights as to what could possibly happen if I did nothing at all?


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## BBCWatcher

I think the risk is low but increasing over time. Governments want revenues, bottom line. Collecting unpaid taxes and/or penalties is a growth business.

If your real U.S. tax liability is zero or negative -- yes, it's occasionally possible for a U.S. citizen living outside the U.S. to receive money from the IRS -- then there's no penalty for nonfiling. But that has to be the real situation, and the IRS can take a shot trying to find otherwise if if wants. So far the IRS hasn't done much to pursue nonfilers with reasonably modest incomes living overseas, but who knows what the future will bring.

I get more concerned about FBARs which are something like the "Al Capone option." The government couldn't get Capone on, say, murder, but could get him on taxes. Within taxes FBARs are something like that. They provide the Treasury Department with some more clear cut leverage, and that's really the whole point. Truthful FBARs are completely boring to the Treasury. It's what people _don't_ report that's most interesting.

My guess is that Treasury might in the future start sending out "you must file FBARs" letters. Knowledge of FBAR (and nonfiling) is enough to trigger the penalties, and (surprisingly) if you lie to your accountant on a tax survey asking about your non-U.S. accounts even that's enough. But if Treasury can't prove you knew about FBAR (or that you lied to someone in a FBAR-related way), it'd be tough for them to pursue penalties. So that's why I think they'll start sending out letters (or even place phone calls) to see how many nonfilers they then get after warning them. That'd be a way to collect some juicy penalties if they want to be only slightly more aggressive.

Congress periodically flirts with the idea of adding tax compliance to State Department (passports) and or CBP (entry into the U.S.) missions. I think that'll happen at some point. Many countries already do that, requiring "tax clearance" before leaving for example, so I don't think the U.S. will hold out too many more years. Same with things like Social Security -- the U.S. will probably get even better over time enforcing tax compliance through benefit programs.

Anyway, low -- maybe even very low -- but increasing. Good enough?


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## bluewormx

Thanks allot, very good awnser.


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## maz57

Hi bluewormx. After reading your description of your situation I did a quick internet search of the Spanish rules. Spain does not allow dual citizenship except with certain Latin American countries! 

I expect as far as the Spanish government is concerned you are a Spanish citizen and only a Spanish citizen. Therefore the Spanish government would presumably not assist the US government in collecting any US tax liability while you are residing on Spanish soil. 

Of course, the US government has a totally different view on this, considers you a US citizen, and expects you to file US tax returns forever. Unless there are complicating factors which you have not mentioned, it appears to me you have a case for applying for a CLN (Certificate of Loss of Nationality) backdated to 1996 when you became a Spanish citizen. This would have to be done in person at a US consulate. Everything would hinge on establishing your intent at the time of becoming a Spanish citizen. If you intended to lose your US citizenship and did nothing in the meanwhile to exercise it (like voting, using a US passport, filing US returns, and so on) you would have a pretty good case, I think.

If you could shed you're US citizenship in this fashion, I expect you could safely ignore all of the five years of 1040's and the exit tax form (8854). Technically you would then be classified as a "covered expat" but realistically, what could the IRS do about it? If you have no ties to the US, no assets, and no expectation of ever returning, why should you carry this burden any longer.

All of this has to be carefully researched and considered before you make your move; it's been 17 years-no need to rush things at this point. The IRS simply doesn't have the resources to micromanage all of the expats of modest means scattered around the globe. In summary, my take is to combine your two options; i.e. renounce (technically, relinquish) and do nothing taxwise.

Disclaimer: I'm not a lawyer, tax expert, or immigration consultant. This is my take on your situation as you have described it on an internet forum; my .02 only. This course of action is similar to what I have chosen to do personally. It will take years for all of this to play out.


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## Nononymous

My situation is not unlike yours, as I only lived and worked in the US for the first half of the nineties. I am on record as being a big fan of the "if they don't know about you, think long and hard about making your existence known to them" approach. Because right now they don't know, but once they do, there's no turning back. 

Your kids should consider themselves lucky. (And if you change your mind, and it really is only two weeks you need to make up, then presumably you move to the US for three weeks and you're good to go.)

Here's my suggestion.

Filing taxes shouldn't be that hard, and if you're not philosophically opposed to the idea, maybe that's the safe thing to do. But it means they know about you, and you'll be filing for the rest of your days.

Renouncing is pretty straightforward. You can then send them five years worth of paperwork (ballpark numbers are probably okay if you don't owe anything) and be done with it. Or pull a fast one and try to do it without.

If you choose to remain non-compliant, which is probably what I'd do (because I'm, um, a rebel) then there are two issues you need to think about:

1. If you ever want to visit the US, then you really should have a US passport, if you have a US birthplace. It be the law. Obtaining a US passport may (or may not, for all we know) alert the IRS to your existence. At least now you are only requited to add your SSN to the application and sign a little declaration that it's true; a few years ago you were required to sign a little oath that your taxes were up to date, but thankfully that has disappeared.

2. Think if there is anything in your Spanish banking records that would make you look like a US citizen - a record of your birthplace associated with bank accounts (which you presumably opened as a Spanish citizen). If there is, that may one day cause your existence to become known to the US.

All in all, you could most likely ignore this as long as you intend to remain in Spain and not return to the US. You're a Spanish citizen living in Spain. You likely owe no US taxes. There's the goofy FBAR thing but really, what are the odds of the US assessing a penalty and collecting anything if you stay put and are a small fish?

On the other hand, it's not that difficult to become compliant - if you can hold your nose and do so. (I'm not, but I recognize that my decision is not entirely rational. I'm driven by a strange mixture of laziness and contrariness.)


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## BBCWatcher

There is however the fact that the Spanish economy is in a dire situation, and the Spanish government is particularly highly motivated to collect unpaid taxes and penalties. Thus Spain will likely be enthusiastic about exchanging data with, among others, the U.S. -- to find the individuals owing Spain.

I really don't know the amount of risk now. "Probably low" is my best, imprecise guess. Increasing? Yes, that's a pretty safe bet. Increasing from extremely low to very low, or increasing from low to moderate? I have no idea.

"Increasing" combined with "I don't know how much" would make me inclined to take the penalty free deal on offer. But that's how I would assess that situation, not the only way it could be assessed. There are also CLN/renunciation options.


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## Bevdeforges

I've been travelling and so am just catching up with the posts here on the board while I was "up in the air."

At the moment, the risk of your being sought out by the IRS for failure to file (tax returns or FBAR forms) is minimal, as long as you haven't somehow managed to come up on the IRS' radar. How long that will remain the case is hard to tell.

You are by no means the only US citizen living abroad who didn't realize they were supposed to file - and to be honest, the IRS resources to check compliance outside the US are limited at best. Even within the US, you have to have somehow come to their attention before they start audit or other procedures against you.

Now, what will happen with this FBAR stuff is anyone's guess. This year they are requiring all FBAR reporting to be done online, but there seems to be no exception procedure for people who honestly don't have a computer or Internet access. (I have a friend in this situation.) There is also the matter of whether or not foreign banks are simply going to give the IRS a data dump on anyone who "might" have US ties. The big banks with US offices, sure, will comply - but smaller regional banks may not have quite the motivation to comb their records for "potential" US persons.

It's really a matter of you plays the game and you takes your chances. And yes, it could change in the future.
Cheers,
Bev


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## bluewormx

I am really greatfull to everyone for spending the time and thought to awnser in this thread.

Over the last three days I have been kicking about my options, The wisdom I have perceived from those that have written here and certain other experiances in the last three days have led me to the point where I am going to try to get compliant.

Do I like it? NO!

Do I feel that as a point of principal I should not ? YES!

Do I think that the Spanish government going along with FATCA is little more than "Un brindis al sol" (a toast to the sun), kisses on the wind if you will. YES!

Never the less I filed out the DS-4079 and in all honesty I have never had an intention to relinquish my US citizenship, I voted in 2008 and I renewed my passport less than three months ago.

I certainly feel for the moment I'm ok but this world we are living in is changing fast. Just yesterday to transfer 600USD from my only US account I had to awnser security questions based on public data which some computer spider put together, it blew my mind. Orwells predictions where only off 30 years!
Data protection is a joke. As many have said the day will come when I wont be ok.
Thanks again.


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## Nononymous

If you recently renewed your passport, then (theoretically at least) the IRS will have record of a US citizen with a given SSN living at a given address in Spain. 

In that case, compliance is probably your best option.


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## bluewormx

I Looked over IRS pub 54, and it raised a few questions.
Do I have to declare my NRA spouses earnings? 
Can I not claim my 2 NRA children as dependents?

My NRA kids each has a savings account in their respective names, my wife and I are signatories do I have to send FBAR on those?


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## Bevdeforges

The simple answer is that no, you do not have to declare anything (income or accounts) for your NRA spouse and children, if they don't have US citizenship. That said, if you hold accounts in joint name with any of them, then yes, you do need to declare those accounts on your FBAR form. For the spouse, at least, you can simply indicate "spouse, NRA" rather than having to give name and taxpayer number. For the kids, I would just give their names and NRA for the ITIN with no relationship information.

To take the kids (or anyone, for that matter) as a dependent they MUST have an ITIN or social security number.
Cheers,
Bev


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## bluewormx

Thanks Bev,
I got ahead of my self with my kids accounts since neither has been >10k

But for the future it sound like it would be wise to remove myself from their accounts, and likewise my spouses.

If none of my accounts has ever been over 10k, do I still need to file FBAR, or if the banc erases data after 3 years and I don't know myself?


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## BBCWatcher

Read the instructions carefully: $10K or more _total_. A pair of $5000 accounts is enough, for example.


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## bluewormx

Thanks BBVCwatcher, have now read the FBAR guide, seems straight forward enough.
A few more what if's...

What if account data for say 2007 is unavailable because banc only keeps data 3 years?

What is the deal with FATCA form 8938.

Wont FBAR be pointless once FATCA comes online in 2014.


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## Bevdeforges

FATCA forms and FBAR forms are two very different things.

FATCA forms are filed along with your annual tax return. And if you aren't required to file a tax return (i.e. because your total gross income falls below the filing threshold for your filing status) you do not have to file the FATCA forms.

The FBAR form is a separate filing - to the Treasury Dept. and not to the IRS - which must be filed if you have $10,000 or more cumulative total in foreign accounts over which you have signature authority (separately or jointly with others). Even if you aren't required to file a tax return, you are still required to file an FBAR report if you meet the criteria.
Cheers,
Bev


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## BBCWatcher

As for the "my bank doesn't keep old data" issue, from now on keep copies of your statements, going back as far as your financial institutions allow. (These days that's pretty easy to do with electronic statements if available.) Then take your best, most truthful guess and estimate. Was it a $1,000,000 or $5,000 account at its peak balance for the year? You should have _some_ idea, so take your best (high) guess, which is all you can really do anyway if there are no surviving data.


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## bluewormx

Thanks again BBCwatcher, I've been digging around, and only missing data from when the bank went all e-file. 2010 and 2011 I'm sure they have it.

I've also been having a go at 2555ez and 1040.

2555ez was simple enough.
I'm a bit confused on 1040.

I'm on line 37 $000,00.00

Could'nt lines 38 thru 76 be $000,00.00 also?


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## islander_expat

I'm also in the process of preparing my data for entering the streamlined process. I was born in the US but moved to the Caribbean when i was 4 months old, got dual citizenship when i was 13 years old. I am now 27 and just waking up to my filing obligations and FBARs. 

The strange thing is that i've always renewed my US passport at the local consulate but was never informed of my filing obligations. I just assumed that because i was paying taxes in my country of residence i did not have to file with the US. oh well..... i know what i have to do now and want to get into compliance. However, I don't want to be penalized for not being aware of my obligations.

I've probably only been sleeping for about 2 hrs every night since i found out about 3 weeks ago.


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## BBCWatcher

islander_expat said:


> The strange thing is that i've always renewed my US passport at the local consulate but was never informed of my filing obligations.


You were informed in writing. Take a look inside your U.S. passport where you'll find a tax notice. Isn't the U.S. Department of State helpful? 

You're not the first person to miss that notice. I'm not suggesting otherwise and certainly not criticizing you for missing it.


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## islander_expat

Oh my God! Why wouldn't they tell you to look at this, the only time i've used my passport is to present to a CBP officer, then it goes back into my pocket. I feel like such a clutz...does this mean i won't be able to prove reasonable cause when going through the streamlined process?

I am not a criminal, i am just a normal person and not rich in the slightest. I was just unadvised and now i am scared for my life. I want to do the right thing but I can't stand the thought of being bankrupt or in prison for something like this.


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## Bevdeforges

Don't lose any sleep over this. There are lots of people out there who have been living overseas for years, but still don't realize that they are supposed to be filing US taxes.

Make a good faith effort to get up to date, depending on your particular situation. As long as you don't owe anything (or more than a couple hundred bucks or so) for the prior years that you are filing, chances are nothing will ever be said or done.

And the fact that you're only 27 means that, as long as you don't have unusally large or complex investments or accounts, you can probably get by with just starting to file now and just don't bother with the back filings. It's perfectly normal for young people not to have to file (due to the filing thresholds) before they are 25, 26, 27 years old. That's not an official policy or position, but from experience, I've seen very few people ever get hassled if they start filing at age 27.
Cheers,
Bev


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## Nononymous

islander_expat said:


> Oh my God! Why wouldn't they tell you to look at this, the only time i've used my passport is to present to a CBP officer, then it goes back into my pocket. I feel like such a clutz...does this mean i won't be able to prove reasonable cause when going through the streamlined process?
> 
> I am not a criminal, i am just a normal person and not rich in the slightest. I was just unadvised and now i am scared for my life. I want to do the right thing but I can't stand the thought of being bankrupt or in prison for something like this.


Dude, relax. This isn't a problem. You are becoming slightly hysterical. 

Millions and millions of US citizens abroad are non-compliant with absolutely no ill effects. Some of us even know all about our filing obligations but have made a considered decision to remain non-compliant, figuring that it's better to stay off the radar.


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## islander_expat

I am sorry if i sounded hysterical, I guess my frustration is getting the better of me. The reason is that there is so much ambiguity with the US tax laws that trying to wrap my head around it for the first time is difficult. Reading too much can be educational but it can also inject copious amounts of paranoia into your system.

The reason i want to be compliant is that I don't want to have any major complications in the future that could affect my NRA Spouse and Daughter. I have a few accounts which generate very little interest and my income from wages is less than the foreign earned income exclusion. Would there be any benefits of going through the streamlined process vs a "going forward approach"?


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## BBCWatcher

islander_expat said:


> Would there be any benefits of going through the streamlined process vs a "going forward approach"?


Yes, probably. The first benefit is you'd come into compliance with the law (the FBAR part in particular), and that's nice all by itself.

The second potential benefit is that you might receive money from the IRS. For example, assuming you had some earned income in 2010 (but not too much) you may be able to get $400 via the Making Work Pay Tax Credit. (Though you have to file soon for that one.) You might also qualify for the Additional Child Tax Credit, but that's a little less clear.

Maybe that's not going to happen, but run the numbers (without the FEIE first, using the Foreign Tax Credit, and tax year 2010 first). If any tax year is going to result in a negative tax rate for you that'd probably be the one, especially if your child was born in that year or prior. If you run the calculation and discover the IRS owes you money, great, get at least your 2010 tax return to the IRS before April 15, 2014. (If you need to stretch that deadline to June 15, 2014, you might be able to -- come back and ask if need be -- but I wouldn't risk it if the IRS owes you money.)

Yes, it's possible to be a U.S. citizen living outside the U.S. and be entitled to receive money from the IRS. That's how Congress wrote the tax code, quite intentionally. The tax code is sometimes used to pump money into the economy and into particular households.


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## islander_expat

BBCWatcher said:


> Yes, probably. The first benefit is you'd come into compliance with the law (the FBAR part in particular), and that's nice all by itself.
> 
> The second potential benefit is that you might receive money from the IRS. For example, assuming you had some earned income in 2010 (but not too much) you may be able to get $400 via the Making Work Pay Tax Credit. (Though you have to file soon for that one.) You might also qualify for the Additional Child Tax Credit, but that's a little less clear.
> 
> Maybe that's not going to happen, but run the numbers (without the FEIE first, using the Foreign Tax Credit, and tax year 2010 first). If any tax year is going to result in a negative tax rate for you that'd probably be the one, especially if your child was born in that year or prior. If you run the calculation and discover the IRS owes you money, great, get at least your 2010 tax return to the IRS before April 15, 2014. (If you need to stretch that deadline to June 15, 2014, you might be able to -- come back and ask if need be -- but I wouldn't risk it if the IRS owes you money.)
> 
> Yes, it's possible to be a U.S. citizen living outside the U.S. and be entitled to receive money from the IRS. That's how Congress wrote the tax code, quite intentionally. The tax code is sometimes used to pump money into the economy and into particular households.


Thanks for that, i understand that the IRS might owe me money but i'm not really concerned about collecting. I feel bad enough knowing that i wasn't complying to their laws that i just want to get my stuff filed, pray for no penalties and start being compliant going forward.


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## BBCWatcher

islander_expat said:


> Thanks for that, i understand that the IRS might owe me money but i'm not really concerned about collecting.


Just run the calculation and see what you get: tax year 2010, Make Work Pay Tax Credit and (if eligible) Additional Child Tax Credit, Foreign Tax Credit but not FEIE. Start with that specific calculation and see what you've got. If the result is negative (i.e. a refund) then congratulations.


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## islander_expat

*Finally did it*

Well...i finally did it. I got all my info together (hoping to god everything is correct) hired a tax attorney, they prepared my returns and FBARs and the questionnaire and it will be ready to be submitted to the IRS by this week for the streamlined filing.

I am happy to get this out of the way but also scared as hell because i know the worst part is yet to come.

What can i expect once it reaches the IRS? Do they contact me directly or would they contact my attorney/tax preparer?


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## Bevdeforges

Congratulations! (Especially if you have money coming back.)

Attorney or not, you are ultimately responsible for your income tax returns and filings. Basically, if they have any questions, they'll be in touch with you. But this is one of those cases where no news is good news.
Cheers,
Bev


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## islander_expat

Bevdeforges said:


> Congratulations! (Especially if you have money coming back.)
> 
> Attorney or not, you are ultimately responsible for your income tax returns and filings. Basically, if they have any questions, they'll be in touch with you. But this is one of those cases where no news is good news.
> Cheers,
> Bev



So would i receive a letter stating that : Hey, we know you screwed up, we're not imposing any penalties, welcome to form-country?

I intend to continue filing for 2013 and onwards as well just to make sure i'm compliant.


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## Bevdeforges

islander_expat said:


> So would i receive a letter stating that : Hey, we know you screwed up, we're not imposing any penalties, welcome to form-country?
> 
> I intend to continue filing for 2013 and onwards as well just to make sure i'm compliant.


Definitely the best approach. You might (possibly) receive a letter some day saying that "ok, all is well" - but then again you might not. If you actually receive a check or deposit for the money they owe you, that's a very good sign.
Cheers,
Bev


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## islander_expat

Bevdeforges said:


> Definitely the best approach. You might (possibly) receive a letter some day saying that "ok, all is well" - but then again you might not. If you actually receive a check or deposit for the money they owe you, that's a very good sign.
> Cheers,
> Bev




Well actually, I owe zero taxes and none of the returns signaled a refund. But i will be happy to just get this filed and come into compliance. It's the uncertainty of not knowing your fate that kills you. So far i seem to qualify with no additional risk factors, so it's just to pray and pray hard.

Thanks for all your kind words bev and BBCwatcher, what i plan to do is create a timeline of my experience from start to finish as there isn't much info on persons utilizing the Streamlined process.

Will keep you guys updated as it progresses.


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## BBCWatcher

A few months from now you could order a tax transcript as verification. It's free. Maybe do that in mid-2014 a couple months after your 2013 filing?


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## islander_expat

BBCWatcher said:


> A few months from now you could order a tax transcript as verification. It's free. Maybe do that in mid-2014 a couple months after your 2013 filing?



Didn't know i could do that....I tried researching to see if the IRS will send you a letter saying you've been accepted into the streamlined but couldn't find anything. 

For one of the 6 years i wasn't even required to file a FBAR because i was under the 10000 aggregate; so i think they will contact me because they might assume it's missing from the total submission.


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## FFMralph

Just for your Information. I am a programmer for a large German bank. We have just completed the programs to locate american citizens who live abroad for the the purpose of sharing tax data. The Determination is based on:
-- an american passport was used when opening an account
-- an account holder has already stated he is american
The following will cause an account to be flagged for further Determination: 
-- the last or first name could be an american (english) name.
-- contact addresses or telephone numbers are in the U.S.

These are just a few. 
Implementation and followup are to begin *July 2014* !


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## compostelle

FFMralph said:


> Just for your Information. I am a programmer for a large German bank. We have just completed the programs to locate american citizens who live abroad for the the purpose of sharing tax data. The Determination is based on:
> -- an american passport was used when opening an account
> -- an account holder has already stated he is american
> The following will cause an account to be flagged for further Determination:
> -- the last or first name could be an american (english) name.
> -- contact addresses or telephone numbers are in the U.S.
> 
> These are just a few.
> Implementation and followup are to begin *July 2014* !


This is very interesting news as to how banks will be looking at account holders in Germany. My question is, how will the german banks look at accounts for someone that has (for example) a Canadian Passport that lists the USA as place of birth? My Canadian passport expires next year and I am considering not having my place of birth included in my next Canadian passport. I have close ties to Germany and will eventually need to open a bank account there. Also, I would like to know if the lack of place of birth in a passport will cause any difficulties. Thanks for any help!


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## FFMralph

Based on your place of birth, the program will flag you as a *possible* american citizen. A bank employee will then investigate your records or make contact to determine your citizenship. All forign financal institutions who have a presence in the U.S. are doing everything they can to avoid the stiff fines U.S. penalties.


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