Form 14654 – Fill Out and Use This PDF

Note: If this certification is a joint certification, the statements will be considered made on behalf of both spouses, even though the pronoun “I” is used. If spouses submitting a joint certification have different reasons for their failure to report all income, pay all tax, and submit all required information returns, including FBARs, they must state their individual reasons separately in the required statement of facts.

Certification

I am providing amended income tax returns, including all required information returns, for each of the most recent 3 years for which the U.S. tax return due date (or properly applied for extended due date) has passed. I previously filed original tax returns for these years. The tax and interest I owe for each year are as follows

Total

I failed to report income from one or more foreign financial assets during the above period.

I meet all the eligibility requirements for the Streamlined Domestic Offshore procedures.

If I failed to timely file correct and complete FBARs for any of the last 6 years, I have now electronically filed those FBARs.

During each year in either my 3-year covered tax return period or my 6-year covered FBAR period, my foreign financial assets subject to the 5% miscellaneous offshore penalty were as follows

Year

	Name, City, and Country of		Year Account Was	Year-End Balance/
		Account Number	Opened or Asset	Asset Value
	Financial Institution/Description of Asset
			Was Acquired	(state in US Dollars)
	Total

If you held no assets subject to the 5% miscellaneous offshore penalty during this year enter “N/A” next to “Total” in the above table. Attach a continuation sheet if necessary. If you attach a continuation sheet, it must be signed with taxpayer name(s) and TIN(s) printed.

Year

	Name, City, and Country of		Year Account Was	Year-End Balance/
		Account Number	Opened or Asset	Asset Value
	Financial Institution/Description of Asset
			Was Acquired	(state in US Dollars)
	Total

If you held no assets subject to the 5% miscellaneous offshore penalty during this year enter “N/A” next to “Total” in the above table. Attach a continuation sheet if necessary. If you attach a continuation sheet, it must be signed with taxpayer name(s) and TIN(s) printed.

Catalog Number 67044W

www.irs.gov

Form 14654 (Rev. 9-2017)

				Page of
	Year
	Name, City, and Country of		Year Account Was	Year-End Balance/
		Account Number	Opened or Asset	Asset Value
	Financial Institution/Description of Asset
			Was Acquired	(state in US Dollars)
	Total

If you held no assets subject to the 5% miscellaneous offshore penalty during this year enter “N/A” next to “Total” in the above table. Attach a continuation sheet if necessary. If you attach a continuation sheet, it must be signed with taxpayer name(s) and TIN(s) printed.

Year

	Name, City, and Country of		Year Account Was	Year-End Balance/
		Account Number	Opened or Asset	Asset Value
	Financial Institution/Description of Asset
			Was Acquired	(state in US Dollars)
	Total

If you held no assets subject to the 5% miscellaneous offshore penalty during this year enter “N/A” next to “Total” in the above table. Attach a continuation sheet if necessary. If you attach a continuation sheet, it must be signed with taxpayer name(s) and TIN(s) printed.

Year

	Name, City, and Country of		Year Account Was	Year-End Balance/
		Account Number	Opened or Asset	Asset Value
	Financial Institution/Description of Asset
			Was Acquired	(state in US Dollars)
	Total

If you held no assets subject to the 5% miscellaneous offshore penalty during this year enter “N/A” next to “Total” in the above table. Attach a continuation sheet if necessary. If you attach a continuation sheet, it must be signed with taxpayer name(s) and TIN(s) printed.

Year

	Name, City, and Country of		Year Account Was	Year-End Balance/
		Account Number	Opened or Asset	Asset Value
	Financial Institution/Description of Asset
			Was Acquired	(state in US Dollars)
	Total

If you held no assets subject to the 5% miscellaneous offshore penalty during this year enter “N/A” next to “Total” in the above table. Attach a continuation sheet if necessary. If you attach a continuation sheet, it must be signed with taxpayer name(s) and TIN(s) printed.

Note: Use this seventh year only if your 3-year covered tax return period does not completely overlap with your 6-year covered FBAR period (for example, if your 3-year covered tax return period is 2011 through 2013 because the due date for your 2013 tax return is passed, but your covered FBAR period is 2007 through 2012 because the due date for the 2013 FBAR has not passed).

Catalog Number 67044W

www.irs.gov

Form 14654 (Rev. 9-2017)

				Page of
	Year
	Name, City, and Country of		Year Account Was	Year-End Balance/
		Account Number	Opened or Asset	Asset Value
	Financial Institution/Description of Asset
			Was Acquired	(state in US Dollars)
	Total

If you held no assets subject to the 5% miscellaneous offshore penalty during this year enter “N/A” next to “Total” in the above table. Attach a continuation sheet if necessary. If you attach a continuation sheet, it must be signed with taxpayer name(s) and TIN(s) printed.

The assets listed in this certification are my only foreign financial assets subject to the 5% miscellaneous offshore penalty.

My penalty computation is as follows

Highest Account Balance/Asset Value (enter the highest total balance/

asset value among the years listed above)

Miscellaneous Offshore Penalty (Highest Account Balance/Asset Value from above multiplied by 5%)

My payment information is as follows

Total Tax and Interest Due

Miscellaneous Offshore Penalty

Total Payment

Note: Your payment should equal the total tax and interest due for all three years, plus the miscellaneous offshore penalty. You may receive a balance due notice or a refund if the tax, interest, or penalty is not calculated correctly.

In consideration of the Internal Revenue Service’s agreement not to assert other penalties with respect to my failure to report foreign financial assets as required on FBARs or Forms 8938 or my failure to report income from foreign financial assets, I consent to the immediate assessment and collection of a Title 26 miscellaneous offshore penalty for the most recent of the three tax years for which I am providing amended income tax returns. I waive all defenses against and restrictions on the assessment and collection of the miscellaneous offshore penalty, including any defense based on the expiration of the period of limitations on assessment or collection. I waive the right to seek a refund or abatement of the miscellaneous offshore penalty.

I agree to retain all records (including, but not limited to, account statements) related to my assets subject to the 5% miscellaneous offshore penalty until six years from the date of this certification. I also agree to retain all records related to my income and assets during the period covered by my amended income tax returns until three years from the date of this certification. Upon request, I agree to provide all such records to the Internal Revenue Service.

My failure to report all income, pay all tax, and submit all required information returns, including FBARs, was due to non-willful conduct. I understand that non-willful conduct is conduct that is due to negligence, inadvertence, or mistake or conduct that is the result of a good faith misunderstanding of the requirements of the law.

I acknowledge the possibility that amended income tax returns I am submitting under the Streamlined Domestic Offshore Procedures may report income for tax years beyond the three-year assessment limitations period under I.R.C. § 6501(a). Other assessment limitations periods in I.R.C. § 6501 may allow the Internal Revenue Service to assess and collect tax. If I seek a refund for any tax or interest paid for the omitted income that I am reporting on my amended income tax returns because I feel that my payments were made beyond the assessment limitations period, I understand that I will forfeit the favorable terms of the Streamlined Procedures.

I recognize that if the Internal Revenue Service receives or discovers evidence of willfulness, fraud, or criminal conduct, it may open an examination or investigation that could lead to civil fraud penalties, FBAR penalties, information return penalties, or even referral to Criminal Investigation.

Note: You must provide specific facts on this form or on a signed attachment explaining your failure to report all income, pay all tax, and submit all required information returns, including FBARs. Any submission that does not contain a narrative statement of facts will be considered incomplete and will not qualify for the streamlined penalty relief.

Catalog Number 67044W

www.irs.gov

Form 14654 (Rev. 9-2017)

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Provide specific reasons for your failure to report all income, pay all tax, and submit all required information returns, including FBARs. Include the whole story including favorable and unfavorable facts. Specific reasons, whether favorable or unfavorable to you, should include your personal background, financial background, and anything else you believe is relevant to your failure to report all income, pay all tax, and submit all required information returns, including FBARs. Additionally, explain the source of funds in all of your foreign financial accounts/assets. For example, explain whether you inherited the account/asset, whether you opened it while residing in a foreign country, or whether you had a business reason to open or use it. And explain your contacts with the account/asset including withdrawals, deposits, and investment/ management decisions. Provide a complete story about your foreign financial account/asset. If you relied on a professional advisor, provide the name, address, and telephone number of the advisor and a summary of the advice. If married taxpayers submitting a joint certification have different reasons, provide the individual reasons for each spouse separately in the statement of facts. The field below will automatically expand to accommodate your statement of facts.

Under penalties of perjury, I declare that I have examined this certification and all accompanying schedules and statements, and to the best of my knowledge and belief, they are true, correct, and complete.

Catalog Number 67044W

www.irs.gov

Form 14654 (Rev. 9-2017)

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For Estates Only

For Paid Preparer Use Only (the signature of taxpayer(s) or fiduciary is required even if this form is signed by a paid preparer)

Signature of Preparer	Name of Preparer			Date
Firm’s name				Firm’s EIN
Firm’s address	City		State	ZIP code
Telephone number	PTIN			Check if
				Self-Employed
Do you want to allow another person to discuss this form with the IRS		Yes (complete information below)		No
Designee’s name			Telephone number

Privacy Act and Paperwork Reduction Notice

We ask for the information on this certification by U.S. person residing in the United States for streamlined domestic offshore procedures to carry out the Internal Revenue laws of the United States. Our authority to ask for information is sections 6001, 6109, 7801, 7803 and the regulations thereunder. This information will be used to determine and collect the correct amount of tax under the terms of the streamlined filing compliance program. You are not required to apply for participation in the streamlined filing compliance program. If you choose to apply, however, you are required to provide all the information requested on the streamlined certification. You are not required to provide the information requested on a document that is subject to the Paperwork Reduction Act unless the document displays a valid OMB control number. Books or records relating to a document or its instructions must be retained as long as their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return information are confidential, as required by section 6103. Section 6103, however, allows or requires the Internal Revenue Service to disclose or give this information to others as described in the Internal Revenue Code. For example, we may disclose this information to the Department of Justice to enforce the tax laws, both civil and criminal, and to cities, states, the District of Columbia, and U.S. commonwealths or possessions to carry out their tax laws. We may also disclose this information to other countries under a tax treaty, to federal and state agencies to enforce federal nontax criminal laws, or to federal law enforcement and intelligence agencies to combat terrorism. Failure to provide this information may delay or prevent processing your application. Providing false information may subject you to penalties. The time needed to complete and submit the streamlined certification will vary depending on individual circumstances. The estimated average time is: 8 hours

Catalog Number 67044W

www.irs.gov

Form 14654 (Rev. 9-2017)