Updated November 2026 · VG CPA PC advisors
Streamlined Domestic Offshore Procedures (SDOP)
SDOP is for US residents who previously filed tax returns for the covered years. You file amended returns for the three most recent years with past-due returns, FBARs for six years, and pay tax, interest and a 5% miscellaneous offshore penalty on the highest year-end aggregate value of the unreported foreign assets.
The certification on Form 14654 must describe why the failure was non-willful in specific, credible terms.
Streamlined Foreign Offshore Procedures (SFOP)
SFOP is for people who meet the non-residency test: for US citizens and green card holders, being physically outside the US for at least 330 full days and not having a US abode in at least one of the three most recent years. Original late returns or amended returns can be filed.
There is no miscellaneous offshore penalty under SFOP. The certification is on Form 14653. Many people who recently moved to the US from India or elsewhere qualify based on an earlier year abroad.
Choosing and preparing
Neither program is available to people under examination or investigation, and neither protects willful conduct. The covered years must be prepared completely, including PFIC calculations and foreign tax credits.
Before filing, confirm whether the Delinquent FBAR procedures would be enough, since they carry no penalty if all income was already reported.