The short answer
To become tax compliant before renouncing, you file every U.S. tax return, FBAR and information return you were required to file for the five tax years before the year you renounce. Most Americans abroad who are behind do this under the IRS Streamlined Foreign Offshore Procedures, which removes penalties for non-willful filers.
5 years
of U.S. tax returns
6 years
of FBARs
Form 14653
certifies non-willfulness under Streamlined
Once you are caught up, you attend your renunciation appointment. Then you file a final dual-status return with Form 8854, where you certify those five years of compliance.
This guide is for people who have decided to renounce and want to do it properly. If you are still deciding whether to renounce at all, start with our answers to the most common questions about renouncing U.S. citizenship.
What “tax compliant” means when you renounce
Form 8854 (the Initial and Annual Expatriation Statement) asks you to certify, under penalty of perjury, that you met all of your federal tax obligations for the five tax years before the year of expatriation. In practice, being compliant means three things are filed and correct for those years.
U.S. federal income tax returns (Form 1040)
You need a return for each year you were required to file. That applies even if:
- you paid tax in your country of residence;
- all your income was foreign; or
- you owed nothing to the IRS after the foreign tax credit or the foreign earned income exclusion.
The U.S. taxes its citizens wherever they live, so filing obligations don’t stop when you move abroad.
FBARs (FinCEN Form 114)
You must file an FBAR for each year the combined balance of your foreign accounts went over $10,000 at any point in the year. The usual catch-up covers six years of FBARs. See our FBAR filing guide.
Information returns attached to your tax return
These are the forms people most often miss. They are part of compliance too:
- Form 8938 for foreign financial assets
- Form 5471 if you own part of a foreign company
- Form 8621 for foreign mutual funds and ETFs (PFICs)
- Form 3520 for foreign gifts, inheritances and trusts
A return that leaves these out is not a complete return.
Why this matters
Miss the five years, and you become a covered expatriate
If you can’t certify five years of compliance, you are automatically treated as a covered expatriate, even if your net worth and income are far below the exit tax thresholds. Covered expatriates may owe the U.S. exit tax on unrealized gains in their worldwide assets, and gifts or inheritances they later leave to U.S. persons can be taxed.
Becoming compliant first is what keeps an ordinary person out of this regime.
How covered status works: Covered Expatriate vs. Non-Covered Expatriate
What happens if you renounce without filing: Can You Renounce U.S. Citizenship Without Filing Taxes?
How the exit tax is calculated: U.S. Exit Tax Explained
Your options for becoming compliant, and who each one fits
Which route you take depends on what you have and haven’t filed, and why.
Already filed everything for the last five years? You don’t need to catch up. Go ahead and schedule your renunciation appointment at a U.S. embassy or consulate.
Streamlined Foreign Offshore Procedures
The Streamlined Foreign Offshore Procedures are an IRS amnesty program that lets U.S. expats become compliant without risking penalties for past non-filing.
Who it fits
- You live outside the U.S. and meet the program’s non-residency test.
- Your failure to file was non-willful, for example because you didn’t know Americans abroad had to file.
- You have a U.S. Social Security number.
Why we file five years, not three
The regular program requires three years of tax returns and six years of FBARs, with a non-willfulness certification on Form 14653. Because you are renouncing, we recommend filing five tax returns under the Streamlined program, so you can certify five years of compliance and renounce without risking any penalties.
This is exactly why we created our Pre-Renunciation Tax Compliance Package, for anyone eligible for the Streamlined Foreign Offshore Procedures. More detail: Streamlined Before Renouncing.
Regular late filing
Who it fits
- You are only a year or two behind and owe little or no tax.
- You don’t qualify for Streamlined, for example because you don’t meet the non-residency test.
What it involves
You file the missing returns normally, with a reasonable-cause explanation where penalties could apply. Interest and penalties may be charged on any tax owed.
If the failure to file was willful, the Streamlined Procedures are not available. Speak to a professional before you file anything.
Relief Procedures for Certain Former Citizens
Who it fits
Any American who renounces and meets these limits, not only accidental Americans. You must:
- have expatriated after March 18, 2010;
- have a net worth under $2 million; and
- owe a total of $25,000 or less in U.S. tax over the six years covered.
Why it is quicker
This is the one route where you renounce first and file afterward. You book your appointment to renounce U.S. citizenship, then file everything once you have renounced.
Especially useful if you don’t have a Social Security number, or you are an accidental American. But if you do have an SSN and your net worth is under $2 million, you can still use this program. Full eligibility rules: What Are the Relief Procedures for Certain Former Citizens?
Late FBARs only
Who it fits
You filed every tax return and reported all your income, but you missed FBARs.
What it involves
You file the missing FBARs electronically, with a statement explaining why they were late. The IRS has removed its Delinquent FBAR Submission Procedures page, but late filing with a reasonable-cause explanation is still the way to fix this. See IRS Quietly Removes Delinquent FBAR Submission Procedures.
Quick comparison
| Your situation | Usual route | When you renounce |
|---|---|---|
| Not filed, non-willful, SSN, living abroad | Streamlined Foreign Offshore | After filing |
| A year or two behind, little tax due | Regular late filing | After filing |
| Net worth under $2M and $25,000 or less tax over 6 years (incl. accidental Americans, no SSN needed) | Relief Procedures for Certain Former Citizens | Before filing |
| Returns filed, FBARs missing | Late FBARs with explanation | After filing |
| Possibly willful non-filing | Get professional advice first | — |
The order of steps: from catch-up to final return
Except for the Relief Procedures, this is the order we recommend:
Step 1
Review your situation
Work out which years and forms are missing, check whether you have an SSN, and estimate your net worth and average U.S. tax liability. This tells you which route fits, and whether you are close to the covered expatriate thresholds, in which case planning before you renounce matters.
Step 2
Catch up on your filings
Prepare and file the missing returns, FBARs and information returns using the route that fits you. With documents in hand this usually takes a few weeks. Applying for an SSN from abroad can add months, so start that first.
Step 3
Attend your renunciation appointment
You take the oath of renunciation at a U.S. embassy or consulate, and that date is your expatriation date. Waiting times vary a lot by country, so many people request an appointment while the catch-up is still in progress.
Read how to prepare in How to Prepare for a U.S. Renunciation Appointment, and how long the whole process takes in How Long Does It Take to Renounce U.S. Citizenship?.
Step 4
File your final return with Form 8854
For the year you renounce, you file a dual-status return: you are a U.S. citizen until your expatriation date and a nonresident alien after it. It includes:
- the dual-status return and statement;
- Form 8854, where you certify your five years of compliance; and
- a final FBAR if your accounts were over the threshold that year.
Example: if you renounce in 2026, your final return is filed in 2027. Form 8854 is due with that return.
Documents you will need
Gather these before you start. Having them ready is what makes the catch-up take weeks rather than months.
Identity and citizenship
For your file
- Your passports (U.S. and other)
- Your birth certificate or Consular Report of Birth Abroad
- Your Social Security number, or proof that you have applied for one
- The date you acquired any other citizenship
Income
For each year being filed
- Payslips or annual employer statements
- Your foreign tax returns and assessments
- Self-employment or business income records
- Rental income and expenses
- Pension, social security and benefits statements
Accounts and assets
For six years
- Bank, investment and pension account statements showing the highest balance each year
- Statements for any foreign mutual funds or ETFs
- Details of any company you own part of, and any trusts you benefit from
- Details of any large gifts or inheritances received
For Form 8854
As of your expatriation date
- A list of your assets and liabilities with their values on your expatriation date (this is your balance sheet for the net worth test)
How we can help
Get compliant and renounce with confidence
Most people find the tax side the hardest part of renunciation, especially after years of not filing. That’s why we built two packages around exactly the steps above.
Pre-Renunciation Tax Compliance Package
- Five years of federal tax returns, including all required information returns
- Six years of FBARs
- Filed under the Streamlined Foreign Offshore Procedures if you qualify, so there are no penalties for non-willful filers
- Guidance on timing your renunciation appointment
Final Tax Return with Form 8854
- Your dual-status final return and statement
- Form 8854, with your five-year compliance certification and covered expatriate determination
- Final FBAR if required
We have helped hundreds of Americans abroad leave the U.S. tax system properly. Not sure which route fits you? Book a 20-minute consultation with one of our Enrolled Agents, who will review your situation and explain your options.
The consultation costs $50. If you engage us to prepare your returns, we’ll deduct the full $50 from your final bill.
