ANCPA Auditing is led by Ashraf Noureldin, a California licensed CPA. The firm prepares USA tax filings for people across the UAE and the GCC: USA citizens and green card holders, non-Americans with any USA income, active or passive, and anyone married to a USA citizen.
Who it is for
- USA citizens and green card holders who live outside the USA.
- In at least one of the last 3 years, you had no home in the USA and spent at least 330 full days outside it.
- Your failure to file was not on purpose: a mistake, carelessness or a genuine misunderstanding of the rules.
- The IRS has not already opened an examination of your returns.
What you file
- Your USA tax returns for the last 3 years whose due date has passed, with any forms that should have gone with them, such as Form 5471 or Form 8938.
- Your FBARs, the reports of accounts outside the USA, for the last 6 years whose due date has passed.
- A signed statement, Form 14653, that you qualify and that the failure was not on purpose.
- Any USA tax due for those years, with interest, paid with the returns.
The returns are sent on paper to an IRS address used only for these filings. The FBARs are filed online.
What you get
If you qualify and follow the steps, the IRS does not charge the penalties for filing late, paying late, missing information forms or missing FBARs. For many people in the Gulf the tax itself is small or nil, because USA reliefs such as the Foreign Earned Income Exclusion apply.
Your options
- Option A: the Streamlined procedures. For people abroad whose failure was not on purpose. 3 years of returns, 6 years of FBARs, one signed statement. The penalties are not charged.
- Option B: file the late returns the normal way. The returns are accepted, but the penalties for filing and paying late can still be charged.
- Option C: the failure was on purpose. The Streamlined statement cannot be signed. You need advice on another route before anything is filed.
Before you start
- The statement you sign must be true. If the failure was on purpose, this route is not for you, and you need advice first.
- Do not file the missing years one by one through the normal route before you talk to us. The order and the route matter.
Questions to ask yourself
- Am I a USA citizen or green card holder living in the UAE or the GCC?
- Did I miss USA returns or FBARs for any of the last 6 years?
- Has the IRS already written to me about those years?
In short
- If you live abroad and missed returns by mistake, the Streamlined procedures are usually the best route.
- It must be before the IRS opens an examination, so do not wait for a letter.
- Many people in the Gulf owe little or no tax for those years, but the forms still have to be filed.
About the author
Ashraf Noureldin is a USA CPA (California) and UAE Tax Agent with more than 25 years in accounting, audit and tax. He founded ANCPA Auditing L.L.C, an audit and tax firm in Emirates Towers, Dubai. USA returns are prepared and signed in Dubai and e-filed through our USA associates in Texas and California. For a question about your own case, email info@cpaauditing.ae, call +971 4 319 7316 or WhatsApp +971 56 620 0575.
This article is general information only. It is not tax, legal or financial advice for any person or company. Take advice on your own facts before you act.