US Lawful Permanent Residents — green card holders — living in the UK occupy a substantively different position from US citizens living in the UK in some respects, but face identical US tax filing obligations in nearly every dimension that matters for compliance. The IRS treats green card holders identically to US citizens for federal income tax purposes under IRC Section 7701(b)(1)(A), meaning the worldwide income reporting requirement, FBAR obligations under the Bank Secrecy Act, FATCA disclosures under IRC Section 6038D, and the full machinery of US international tax compliance apply to every UK-resident green card holder regardless of how long they've lived in the UK or whether they've maintained any connection to the United States since departure. The substantive issue is that most UK-resident green card holders don't know this. Many believe their UK tax residence and UK PAYE compliance is sufficient. Some assume that years of physical absence from the US have terminated their US tax obligations. Neither assumption is correct.
The IRS Streamlined Program under the Streamlined Foreign Offshore Procedures provides the substantively cleanest voluntary disclosure path for UK-based green card holders with prior US tax compliance gaps — complete waiver of accuracy-related penalties under IRC Section 6662, failure-to-file and failure-to-pay penalties under IRC Section 6651, FBAR penalties under 31 USC 5321, and FATCA penalties under IRC Section 6038D for qualifying non-willful conduct. For UK-resident green card holders specifically, the framework operates identically to that for US citizens, with nuances around LPR status verification, expatriation considerations, and pre-LPR US tax residence analysis that the substantive specialist work addresses carefully.
This piece walks through how UK-based green card holders use the IRS Streamlined Program to fix prior US tax compliance gaps, the substantive eligibility requirements specific to LPR status, the comprehensive submission preparation process, and what the typical specialist engagement delivers—written for green card holders currently living in the UK who need to understand whether Streamlined positioning applies to them and how to navigate the process properly, rather than approaching the IRS unrepresented.
What Is the IRS Streamlined Program?
The IRS Streamlined Program is the IRS Streamlined Filing Compliance Procedures voluntary disclosure framework allowing US taxpayers to remedy prior US tax and information reporting compliance gaps through coordinated submission with complete waiver of accuracy-related penalties under IRC Section 6662, failure-to-file penalties under IRC Section 6651(a)(1), failure-to-pay penalties under IRC Section 6651(a)(2), FBAR penalties under 31 USC 5321, FATCA penalties under IRC Section 6038D, Form 5471 and Form 8865 penalties under IRC Section 6038(b), and Form 3520 and Form 3520-A penalties under IRC Section 6677 for qualifying non-willful conduct.
The framework operates across two main programs, plus a Delinquent FBAR Submission Procedure. The Streamlined Foreign Offshore Procedures (SFOP) applies to taxpayers living outside the United States who meet the 330-day non-residency test. For UK-based green card holders, SFOP applies in nearly all cases. The Streamlined Domestic Offshore Procedures (SDOP) applies to US-resident filers and includes a 5 percent miscellaneous offshore penalty calculated on the highest aggregate year-end balance of unreported foreign financial assets across the six-year FBAR lookback period. The Delinquent FBAR Submission Procedures apply to taxpayers who have filed Form 1040 returns properly but missed FBAR filings only.
For UK-based green card holders specifically, the SFOP submission requires the three most recent years of Form 1040 returns with comprehensive worldwide income reporting plus all applicable schedules and forms, the six most recent years of FBAR filings through the BSA E-Filing System under 31 USC 5314, Form 14653 Certification by US Person Residing Outside of the United States certifying non-willful conduct with substantive narrative explanation, and full payment of any tax due plus statutory interest under IRC Section 6601.
The IRS reference for the Streamlined Filing Compliance Procedures sits at https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures.
Who Qualifies — Green Card Holders in the UK Explained
US Lawful Permanent Residents living in the UK who meet three substantive eligibility conditions qualify for the IRS Streamlined Program under the SFOP framework. The substantive scope covers green card holders across several categories.
Active green card holders currently maintaining LPR status while living in the UK. The substantive obligation continues until formal abandonment of LPR status through Form I-407 submission or determination of abandonment under the long-term resident expatriation rules. Many UK-resident green card holders maintain their green cards over years of UK residence — typically through periodic US visits to maintain their status — without recognizing the ongoing US tax obligation.
Green card holders who initially planned temporary UK residence but whose stays became permanent. The substantive obligation doesn't change based on the original intention versus the actual outcome. Once LPR status is established, US tax obligations continue until formal abandonment, regardless of how the residence pattern evolved.
Former green card holders who abandoned LPR status but had prior US tax filing gaps during the LPR period. The substantive Streamlined positioning addresses the prior LPR-period compliance gaps, even where the current LPR status has been terminated.
Green card holders who never substantively used the LPR status to live in the US. Some individuals acquire LPR status through employment-based or family-based sponsorship but live primarily in the UK throughout. The substantive US tax obligation begins when LPR status is established, regardless of physical presence patterns.
The three eligibility conditions for SFOP positioning are as follows. First, the non-residency test: for at least one of the three most recent tax years for which the US tax return due date has passed, the individual did not have a US abode and was physically outside the United States for at least 330 full days. UK-resident green card holders genuinely living in the UK satisfy this test trivially.
Second, the conduct producing the prior compliance gap must be demonstrably non-willful. Non-willful conduct means conduct resulting from negligence, inadvertence, or mistake, or from a good faith misunderstanding of the requirements of the law. The Bedrosian v United States (3rd Cir 2018) and Bittner v United States (US Supreme Court 2023) frameworks inform the willfulness assessment.
Third, no IRS contact regarding the underlying compliance failure can have occurred.
UK-specific misconceptions for green card holders are worth addressing directly. The misconception that surrendering the green card automatically eliminates back-year obligations is wrong — prior LPR-period obligations continue until properly remediated through Streamlined positioning or other voluntary disclosure framework. The misconception that long UK residence automatically terminates LPR status is wrong — formal abandonment through Form I-407 or a determination of abandonment is required. The misconception that maintaining UK tax compliance is sufficient is wrong — US Form 1040 obligations exist independently. The misconception that UK ISAs and UK pensions don't require US reporting is wrong — all UK financial accounts require FBAR and FATCA analysis identical to those for US citizens.
The IRS reference for green card holders sits at https://www.irs.gov/individuals/international-taxpayers/taxation-of-resident-aliens.
The Core Streamlined Program Considerations Specific to UK-Resident Green Card Holders
LPR Status Verification and Documentation
The IRS Streamlined Program submission for green card holders requires comprehensive documentation to support LPR status throughout the SFOP lookback period. The substantive elements include current green card (I-551) documentation, evidence of LPR status across the relevant tax years (which can include older I-551 versions for the periods before the current card was issued), documentation of any periodic US visits maintaining LPR status, evidence of any abandonment considerations that didn't actually result in formal abandonment, and integration with pre-LPR US tax residence analysis where applicable.
For green card holders who acquired LPR status before the Substantial Presence Test under IRC Section 7701(b)(3) applied, the analysis covers the entire period from LPR acquisition through to the SFOP submission. For green card holders who had US tax residence under the Substantial Presence Test before acquiring LPR status, the analysis also extends to the pre-LPR period.
The substantive specialist work documents LPR status carefully because the SFOP submission depends on the substantive US person status throughout the relevant period. The USCIS reference for LPR status sits at https://www.uscis.gov/green-card.
Article 17 Treaty Election for UK Pension Positions
UK-resident green card holders with UK pension positions face the same Article 17 treaty election considerations as US-citizen UK residents. Without an attached Form 8833 Article 17(1) election to Form 1040 each tax year, UK pension growth taxes are currently treated as US-source for US purposes. SFOP positioning for green card holders typically includes an Article 17 election for the three most recent tax years in the SFOP submission, with ongoing election filing thereafter as standard practice.
For UK-resident green card holders with substantial UK pension accumulation (workplace pensions, UK SIPPs, NHS Pension Scheme, USS pension scheme, UK State Pension contributions, defined benefit scheme positions), the Article 17 election positioning produces material US tax deferral that substantially exceeds the SFOP fee structure across the lookback period and going forward.
The IRS Form 8833 reference sits at https://www.irs.gov/forms-pubs/about-form-8833.
PFIC Considerations for UK Investment Positions
UK-resident green card holders with UK investment positions (UK ISAs, UK SIPPs holding investment funds, UK General Investment Accounts) face PFIC complications under IRC Section 1297, identical to those for US citizens. Default IRC Section 1291 treatment produces a substantial annual US tax cost. A QEF election under IRC Section 1295 or a mark-to-market election under IRC Section 1296 provides alternative treatment. Still, each election must be filed within the timely filing period for Form 1040 (including extensions) for the year of acquisition or qualification.
SFOP submissions for UK-resident green card holders with material UK investment positions typically include Form 8621 PFIC reporting for each UK-domiciled fund position. The substantive analysis addresses whether the default Section 1291 treatment, the mark-to-market election, or PFIC remediation through a transition to US-domiciled ETFs accessible via Saxo UK or Interactive Brokers UK yields the optimal positioning.
The IRS Form 8621 reference sits at https://www.irs.gov/forms-pubs/about-form-8621.
Step-by-Step: How UK-Based Green Card Holders Complete the IRS Streamlined Program
Confirm SFOP eligibility before commencing substantive work. Non-residency test analysis verifying 330 days physically outside the US in at least one of the three most recent tax years. Non-willfulness assessment of the circumstances surrounding the prior compliance gap. Confirmation that no IRS contact has occurred regarding the substantive compliance failure. Verification of current LPR status through I-551 documentation. Specialist work runs the eligibility analysis carefully before proceeding.
Map the comprehensive UK financial position across the SFOP submission lookback. UK bank accounts, UK pension positions, UK ISA positions, UK SIPP positions, UK investment positions, UK rental property, UK self-employment activity, UK partnership positions, UK trust positions, UK private company interests. The mapping drives all subsequent elements of the SFOP submission.
Map LPR status documentation across the lookback period. Current green card documentation. Evidence of LPR status across the three Streamlined years and the six FBAR years. Periodic US visit documentation maintaining LPR status. Any pre-LPR US tax residence analysis where applicable.
Prepare the three most recent years of Form 1040 returns. Comprehensive worldwide income reporting with UK PAYE income, UK self-employment income, UK investment income, and UK pension growth (with Article 17 treaty election to defer the growth). Foreign Tax Credit positioning through Form 1116 under IRC Section 901 with proper basket allocation under IRC Section 904(d). Form 8938 FATCA disclosure where the threshold is met. Form 8621 PFIC reporting, where applicable—other applicable schedules and forms.
Prepare the six most recent years of FBAR filings through the BSA E-Filing System. Comprehensive account-by-account reporting for all reportable UK financial accounts. Maximum balance reporting in USD equivalent. Signature authority positions on UK entity accounts, where applicable. The FinCEN reference sits at https://www.fincen.gov/report-foreign-bank-and-financial-accounts.
Prepare Form 14653 Certification with a comprehensive non-willfulness narrative. Substantive factual context supporting non-willful characterization specific to green card holder positioning. Arrival circumstances in the UK after LPR status was established. Belief about US obligations following the UK relocation. Absence of prior US tax adviser consultation. Catalyst surfacing the obligation. Prompt action to engage specialist work.
Calculate full tax due plus statutory interest under IRC Section 6601—Foreign Tax Credit absorption analysis. Article 17 treaty election positioning, eliminating the current US tax on UK pension growth. PFIC analysis with election positioning, eliminating punitive Section 1291 treatment. The substantive analysis often produces modest underlying US tax despite the multi-year filing gap, given comprehensive Foreign Tax Credit absorption.
Submit the comprehensive SFOP package to the IRS. Three years of Form 1040 returns marked "Streamlined Foreign Offshore" in red ink at the top. Six years of FBAR filings submitted separately through the BSA E-Filing System. Form 14653 Certification with substantive narrative. Tax payment plus statutory interest.
Maintain ongoing compliance immediately following SFOP submission. Annual Form 1040 filing with full Foreign Tax Credit positioning, Article 17 treaty election, and PFIC analysis. Annual FBAR filing through the BSA E-Filing System. Annual Form 8938 FATCA disclosure where the threshold is met.
Address LPR status decisions going forward. Some UK-based green card holders consider formally abandoning LPR status through Form I-407 after substantial UK residence. The substantive analysis under the long-term resident expatriation rules under IRC Section 877A applies to green card holders who held LPR status for any portion of the last 8 of the last 15 years. Exit tax positioning may apply. Specialist work coordinates with US immigration attorneys for the LPR status decision, separate from the tax positioning analysis. The IRS reference on expatriation tax is available at https://www.irs.gov/individuals/international-taxpayers/expatriation-tax.
The Streamlined Filing Compliance Procedures — What UK Green Card Holders Need to Know
The Streamlined Filing Compliance Procedures apply identically to US citizens and US Lawful Permanent Residents. For UK-based green card holders, the Streamlined Foreign Offshore Procedures (SFOP) route applies in nearly all cases, since the 330-day non-residency test is satisfied by virtue of genuine UK residence.
SFOP covers complete waiver of accuracy-related penalties under IRC Section 6662, failure-to-file and failure-to-pay penalties under IRC Section 6651, FBAR penalties under 31 USC 5321 (even at non-willful rates under the post-Bittner perform-per-year framework), FATCA penalties under IRC Section 6038D, Form 5471 and Form 8865 penalties under IRC Section 6038(b) where applicable, and Form 3520 and Form 3520-A penalties under IRC Section 6677 where applicable. The 5 percent miscellaneous offshore penalty that applies under SDOP is waived entirely under SFOP.
The eligibility requirements include the 330-day non-residency test in at least one of the three most recent tax years (UK-based green card holders satisfy this trivially), demonstrably non-willful conduct producing the prior compliance gap (typically satisfied for green card holders who genuinely misunderstood the continuing US obligation following UK relocation), and no IRS contact regarding the substantive compliance failure.
What SFOP covers comprehensively for green card holders: three years of late tax returns with full preparation, six years of FBAR filings, comprehensive penalty waiver across all applicable categories, and Form 14653 Certification with substantive non-willfulness narrative.
The IRS reference sits at https://www.irs.gov/compliance/streamlined-filing-compliance-procedures.
Real UK Expat Scenario — IRS Streamlined Program for a Green Card Holder
Case Study: Patricia Lin — UK-Resident Green Card Holder, 12-Year Compliance Gap, Successful Streamlined Submission
Patricia Lin is a representative fictional profile. She's 49, originally from Taiwan, and obtained US Lawful Permanent Resident status in 2008 through employment-based sponsorship working at a US technology firm in Boston. She lived and worked in Boston for five years before transferring to the firm's London office in 2013. She married Michael (a UK citizen) in 2015, became a UK tax resident upon her arrival in 2013, and built a London-based career over 12 years of UK residence. Her green card has remained valid throughout — she returns to the US approximately twice per year for family visits, maintaining LPR status. She had filed no US tax returns since the 2012 tax year (her last full year of US residence), had filed no FBAR reports during her UK residence period, and had no Form 8938 FATCA disclosures despite UK financial positions well above the threshold.
Patricia's UK financial position at engagement (November 2025):
UK current account at HSBC with an average balance of approximately £12,000. UK savings account at Marcus by Goldman Sachs UK with a balance of approximately £68,000. UK workplace pension (Aviva Stakeholder Pension) with a current value of approximately £185,000. UK self-directed SIPP at Hargreaves Lansdown with a current value of approximately £95,000, holding a mix of UK-domiciled funds and individual UK shares. UK Stocks and Shares ISA at Hargreaves Lansdown with a current value of approximately £52,000, holding UK-domiciled income funds. UK property (London flat) jointly owned with Michael, Patricia's interest is approximately £325,000—no US-source income across the UK residence period. No US bank accounts are maintained.
The compliance gap stretched 12 tax years (2013-2024). The substantive penalty exposure under standard delinquent return positioning was substantial — accuracy-related penalties under IRC Section 6662 at 20 percent of any underpayment, plus failure-to-file penalties under IRC Section 6651, plus FBAR penalties potentially reaching $10,000 per non-willful violation per form per year under the Bittner v United States (US Supreme Court 2023) framework. Cumulative penalty exposure across the 12-year gap could have reached $60,000-$120,000 even under non-willful treatment.
Patricia engaged TaxYork in November 2025 after her UK bank requested FATCA self-certification, which made the compliance gap unavoidable. She had received the bank's request, recognized that she needed to engage with US tax obligations she had been quietly aware of but had never addressed, and sought specialist representation before any IRS contact occurred.
The position assessment over seven weeks established the SFOP framework applied:
Non-residency test satisfied trivially. Patricia had been physically present in the UK for substantially more than 330 days in each of the 2022, 2023, and 2024 tax years, with brief US visits totaling approximately 14-21 days per year. Non-willfulness assessment supported SFOP positioning. Patricia had been aware of US tax filing in general terms but had genuinely believed her UK tax compliance was sufficient, given that she had no US income and lived permanently in the UK. The belief was incorrect but represented a good-faith misunderstanding rather than willful avoidance. No IRS contact had occurred. Active LPR status confirmed through current green card documentation.
SFOP submission preparation across twelve weeks:
Three years of Form 1040 returns (2022, 2023, 2024) prepared with comprehensive worldwide income reporting. UK employment income through PAYE was approximately £92,000-£115,000 across the years. UK self-directed SIPP and workplace pension growth requiring Article 17(1) treaty election. UK ISA and SIPP fund positions producing PFIC complications.
Foreign Tax Credit positioning through Form 1116 with general category basket allocation absorbing UK PAYE tax against US tax exposure on the same income. Substantively, complete absorption, given that UK higher-rate tax exceeded US rates on the relevant income.
Article 17(1) treaty election through Form 8833 attached to each Form 1040 deferring US taxation of UK pension growth.
PFIC analysis on UK-domiciled fund positions inside the Hargreaves Lansdown ISA and SIPP. Mark-to-market election under IRC Section 1296 applied for both positions across the three SFOP years. PFIC remediation strategy established for going forward — transition of UK-domiciled fund positions to US-domiciled ETFs accessible via the Saxo UK platform.
Form 8938 FATCA disclosure for each of the three SFOP years, given that the foreign financial asset threshold was met.
Six years of FBAR filings (2019-2024) through the BSA E-Filing System for the HSBC current account, Marcus UK savings account, workplace pension position, SIPP, and the ISA.
Form 14653 Certification with a comprehensive non-willfulness narrative addressing Patricia's arrival circumstances in 2013 through the company transfer, her good-faith belief that UK tax compliance was sufficient given she had no US income, her absence of advisers who would have alerted her to the obligation, her surprise on receiving the bank's FATCA self-certification request, and her prompt action to engage specialist help.
Tax calculation: Substantively complete Foreign Tax Credit absorption produced very modest underlying US tax across the three SFOP years — approximately $1,800 total for the three years combined, plus statutory interest of approximately $230.
Outcome of the SFOP submission:
IRS acknowledged submission within 10 weeks of filing. IRS processed the submission for acceptance across 8 months. Complete penalty waiver applied across all elements. Underlying US tax of approximately $1,800 plus interest paid at submission. Ongoing compliance established for the 2025 tax year forward. PFIC remediation through ISA and SIPP fund repositioning was completed in August 2026.
Compared to standard delinquent return positioning, the SFOP framework eliminated potential penalty exposure of approximately $60,000-$120,000 across the 12-year compliance gap.
TaxYork fees: £7,400 covering the complete SFOP submission preparation across all three Form 1040 years and six FBAR years, PFIC analysis and mark-to-market election positioning, Article 17 treaty election positioning, Form 14653 non-willfulness narrative preparation, IRS correspondence management through specialist representation, and ongoing compliance establishment.
Patricia's view of SFOP acceptance: "The compliance gap had been weighing on me for years,, but I didn't know how to address it without making things worse. The bank's FATCA request forced the issue. The specialist engagement made the SFOP process manageable — substantively complex documentation that I couldn't have navigated without representation, and comprehensive PFIC analysis on positions I didn't know were problematic. The Article 17 election positioning meant that most of the substantive US tax exposure disappeared through Foreign Tax Credit absorption and pension growth deferral. The 12-year compliance gap closed cleanly."
Contact TaxYork today at hello@taxyork.com or 020-34888606.
Penalties for Non-Compliance — What UK-Based Green Card Holders Risk
The penalty framework for US international tax non-compliance applies materially to UK-based green card holders with multi-year compliance gaps under standard delinquent return treatment.
FBAR penalties under 31 USC 5321 reach up to $10,000 per non-willful violation (clarified by Bittner v United States to apply per form per year rather than per account per year) and up to the greater of $100,000 or 50 percent of the account balance per willful violation per year. Failure-to-file Form 1040 penalty under IRC Section 6651(a)(1) reaches 5 percent per month of the unpaid tax up to a maximum of 25 percent. Failure-to-pay penalty under IRC Section 6651(a)(2) reaches 0.5 percent per month of the unpaid tax with no upper cap. Accuracy-related penalty under IRC Section 6662 reaches 20 percent of any underpayment for substantial understatements. FATCA Form 8938 penalty under IRC Section 6038D reaches $10,000 initial penalty plus continuation penalties up to a maximum of $50,000 per failure. Form 3520 penalty under IRC Section 6677 reaches 35 percent of the value of the unreported distribution or gift.
For UK-based green card holders with multi-year compliance gaps across multiple reporting categories, cumulative penalty exposure can reach $ 50,000–$200,000+ per position. The IRS Streamlined Program under SFOP eliminates the entire penalty exposure for qualifying non-willful conduct.
The IRS penalty reference sits at https://www.irs.gov/payments/international-information-reporting-penalties.
Common Mistakes UK-Based Green Card Holders Make with the Streamlined Program
Assuming UK tax residence and UK PAYE compliance, once obligations are assessed. US tax residence for green card holders continues until formal abandonment through Form I-407 or determination of abandonment. UK PAYE compliance addresses UK obligations only.
Pursuing standard delinquent return submission instead of SFOP. Standard delinquent positioning carries full penalty exposure across all applicable categories. The SFOP framework provides a complete waiver for qualifying non-willful conduct — substantially better positioning that requires specialist analysis to confirm eligibility.
Missing PFIC analysis on UK ISA and SIPP fund positions. Default IRC Section 1291 treatment produces punitive treatment that the SFOP submission must address through proper election positioning or remediation.
Failing to claim Article 17 treaty election on UK pension positions across the SFOP years. UK pension growth taxes are currently for US purposes absent a Form 8833 election. Material consequences for green card holders with substantial UK pension accumulation.
Preparing an inadequate Form 14653 non-willfulness narrative. The IRS conducts a substantive review of the narrative as part of SFOP acceptance. Generic narratives without substantive factual context routinely produce rejection.
Approaching the IRS unrepresented for substantive SFOP positioning. Specialist representation through a US Enrolled Agent under IRS Circular 230 provides direct IRS representation rights essential for proper SFOP positioning.
The US-UK Tax Treaty — How It Affects the Streamlined Program for Green Card Holders
The US-UK Income Tax Convention (1975 as amended) applies to UK-resident green card holders through specific articles relevant to Streamlined Program positioning. Article 1(4) saving clause preserves US tax obligations for US citizens. It applies differently to green card holders — the saving clause analysis for LPRs has nuances under specific circumstances, but generally ults inresults in continuing US tax obligations. Article 17 (pensions) provides the treaty election framework for deferring US taxation of UK pension growth. Article 23 (relief from double taxation) provides the Foreign Tax Credit framework that allows UK tax to be offset against US tax exposure. Article 24 addresses Social Security positioning.
The treaty provides substantive relief through Article 23 Foreign Tax Credit absorption (typically eliminating underlying US tax exposure for UK-based green card holders whose UK tax rates exceed US rates) and Article 17(1) treaty election (deferring US taxation of UK pension growth until distribution).
The treaty does NOT eliminate Form 1040 filing obligations for green card holders, FBAR reporting requirements under 31 USC 5314, FATCA Form 8938 reporting under IRC Section 6038D, or other US international information reporting obligations.
The Treasury reference for the US-UK Tax Treaty sits at https://home.treasury.gov/policy-issues/tax-policy/international-tax.
How TaxYork Helps UK-Based Green Card Holders with the Streamlined Program
TaxYork operates as a specialist US expat tax practice, serving Americans living in the UK as our core service line, with a specific focus on UK-based green card holders. The practice combines US Enrolled Agent credentials under IRS Circular 230, providing direct IRS representation rights with a comprehensive understanding of UK tax positioning, ensuring proper integration. The team regularly handles Streamlined Foreign Offshore Procedures submissions for UK-based green card holders, spanning from straightforward individual positions to complex HNW positions involving UK property, UK business interests, and multi-entity exposure.
The Streamlined Program service for green card holders covers comprehensive eligibility analysis including LPR status verification, non-residency test analysis, and non-willfulness assessment, complete preparation of three most recent years of Form 1040 returns with comprehensive worldwide income reporting plus Foreign Tax Credit positioning through Form 1116 plus Article 17(1) treaty election through Form 8833 for UK pension positions plus Form 8938 FATCA disclosure plus Form 8621 PFIC reporting with election positioning where applicable, six most recent years of FBAR filings through the BSA E-Filing System, Form 14653 Certification preparation with substantive non-willfulness narrative addressing the specific facts and circumstances of UK-resident green card holder positioning, full tax calculation with Foreign Tax Credit absorption analysis, PFIC remediation strategy, IRS correspondence management through specialist representation, ongoing compliance establishment, and coordination with US immigration attorneys where LPR status decisions arise separately from the tax positioning analysis.
The TaxYork team holds Enrolled Agent (EA) credentials under IRS Circular 230, providing direct IRS representation rights across all 50 states. EA status authorizes specialist representation in IRS examinations, appeals, and collections matters. The substantive credentials, combined with a specific US-UK expat focus, produce specialist work that is substantively better than generalist US-based remote preparation that lacks a UK context.
Standard Streamlined Program engagements for UK-based green card holders run £4,800 to £14,400, depending on position complexity. Where the engagement includes substantial PFIC remediation work or HNW positions, the engagement extends accordingly. The substantive penalty exposure eliminated through Streamlined positioning typically ranges from $ 22,500 to $200,000+ for green card holder positions — substantially exceeding the engagement cost.
Contact TaxYork today at hello@taxyork.com or 020-34888606.
Conclusion
Three things worth holding onto. The IRS Streamlined Program under the Streamlined Foreign Offshore Procedures provides the substantively cleanest voluntary disclosure route for UK-based green card holders with prior US tax compliance gaps — complete waiver of accuracy-related penalties under IRC Section 6662, failure-to-file and failure-to-pay penalties under IRC Section 6651, FBAR penalties under 31 USC 5321, even at non-willful rates under the post-Bittner perform-per-year framework, FATCA penalties under IRC Section 6038D, and other applicable penalties for qualifying non-willful conduct. The substantive submission requires the three most recent years of Form 1040 returns with comprehensive worldwide income reporting plus Foreign Tax Credit positioning through Form 1116 plus Article 17(1) treaty election through Form 8833 for UK pension positions plus PFIC analysis with election positioning under IRC Sections 1295 and 1296 where applicable plus Form 8938 FATCA disclosure, six most recent years of FBAR filings through the BSA E-Filing System under 31 USC 5314, Form 14653 Certification with substantive non-willfulness narrative addressing the green card holder positioning specifically, and LPR status documentation across the lookback period. And the Streamlined window remains open for qualifying non-willful conduct without IRS contact. Both conditions can be lost through delay, as FATCA data-matching produces increasing IRS visibility of UK-based green card holder positions each year, making prompt engagement with Streamlined positioning substantively better than delayed engagement, which risks the window closing through IRS identification.
Contact TaxYork today at hello@taxyork.com or 020-34888606.