Introduction If you are a high-net-worth American with a UK private banking relationship at Coutts, Hoare, Drummonds, Cater Allen, Weatherbys, C. Hoare & Co, or another UK private bank that has never been reported to the IRS, the Streamlined Foreign Filing Offshore Procedures framework is the structured amnesty route that brings your position fully compliant […]
If you are a high-net-worth American with a UK private banking relationship at Coutts, Hoare, Drummonds, Cater Allen, Weatherbys, C. Hoare & Co, or another UK private bank that has never been reported to the IRS, the Streamlined Foreign Filing Offshore Procedures framework is the structured amnesty route that brings your position fully compliant with zero penalty exposure for qualifying non-willful taxpayers. Private bank accounts typically hold substantial balances, making penalty exposure under 31 USC 5321 materially significant if the IRS contacts the account holder first. By the end of this guide, you will understand exactly how SFOP applies to HNW private banking positions, the specific complexity factors at HNW scale, the willfulness framing analysis that becomes particularly critical for HNW positions, the case study showing the integrated approach in practice, the common mistakes HNW Americans make with unreported private bank accounts, and the practical engagement framework. This guide is written for HNW Americans in the UK with unreported private bank accounts at Coutts, Hoare, Drummonds, Cater Allen, Weatherbys, and similar UK private banks, US-UK dual citizens with substantial UK private banking relationships, and family office principals managing HNW positions.
The Streamlined Foreign Filing Offshore Procedures (typically abbreviated as SFOP) is the foreign-resident arm of the IRS Streamlined Filing Compliance Procedures created by the Internal Revenue Service in 2012 and substantially expanded in 2014. The framework provides a structured amnesty route for non-willful US taxpayers living outside the United States who have missed US tax filings and have undisclosed offshore accounts.
For UK-based Americans, SFOP applies in almost all cases through the 330-day foreign residency test, which long-term UK residents easily satisfy. The scope under SFOP covers three years of late Form 1040 federal income tax returns with all relevant schedules and information returns, six years of FinCEN Form 114 Foreign Bank Account Report filings through the BSA E-Filing System, calculation and payment of underlying US tax owed plus statutory interest under IRC Section 6601, and the Form 14653 non-willfulness certification signed under penalty of perjury.
The penalty waiver under SFOP is the central benefit. SFOP carries zero FBAR penalty under 31 USC 5321, zero failure-to-file penalty under IRC Section 6651, zero failure-to-pay penalty, zero Form 8938 FATCA penalty under IRC Section 6038D, zero Form 8621 PFIC reporting failure penalty under IRC Section 1298(f), and zero miscellaneous offshore penalty. The taxpayer pays only the underlying US tax owed plus statutory interest from the original due date.
For HNW positions involving unreported UK private bank accounts, the financial stakes are materially higher than for standard expat streamlined work. UK private banks typically hold combined balances of £500,000 to £15 million per relationship across multiple sub-accounts, including current accounts, deposit accounts, fixed-term savings, foreign currency accounts, Lombard credit facilities, and investment management portfolios. The non-willful FBAR penalty under 31 USC 5321 at the inflation-adjusted maximum of $129,210 per report across six years could produce $775,000+ of exposure under the per-report Bittner methodology, with willful penalty exposure under the greater of $100,000 inflation-adjusted or 50 percent of account balance potentially reaching several million dollars. The IRS streamlined filing reference sits at https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures.
The 2026 context has produced three specific drivers that make Streamlined Foreign Filing Offshore Procedures materially more time-sensitive for HNW Americans with unreported private bank accounts than in earlier years.
First, FATCA enforcement reached full operational maturity in 2024 and 2025, with UK private banks now systematically identifying US-citizen account holders through enhanced due diligence procedures applied to all account openings and periodic reviews. Coutts, C. Hoare & Co, Drummonds (part of Royal Bank of Scotland), Cater Allen (part of Santander UK), Weatherbys, Adam & Company, and other UK private banks now apply comprehensive US person identification through US place of birth indicators on passport scans, address records, citizenship status questions, and reasonable belief tests under the US-UK FATCA Intergovernmental Agreement. The IRS operates automated cross-reference workflows that compare FATCA data with filed Form 8938 and FBAR records, generating enforcement contact triggers for identified non-compliance. The IRS FATCA reference sits at https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca.
Second, the IRS Large Business and International Division’s review of streamlined submissions has continued through 2024 and 2025, with particular focus on HNW submissions, including private banking client positions. The refined review applies enhanced screening for willful conduct indicators when high-balance accounts are involved, including substantial balances maintained without reporting, sustained patterns of foreign account use, professional backgrounds suggesting cross-border tax awareness, and indicators of active concealment. Generic Form 14653 narratives unsupported by detailed facts attract scrutiny under the refined review for HNW positions.
Third, the FA 2025 long-term residence framework, which came into force on 6 April 2025, brings UK residents into the UK Inheritance Tax worldwide net at the 10 of 20 years’ residence trigger. HNW Americans with substantial UK private banking relationships face dual US and UK estate exposure to worldwide assets, including private bank balances. Clean US compliance through the streamlined route becomes a prerequisite for cross-border estate planning that protects against the new UK IHT exposure. The HMRC framework reference sits at https://www.gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals.
The first core layer of Streamlined Foreign Filing Offshore Procedures work for HNW private banking clients is the high-stakes willfulness framing analysis. The non-willful conduct standard under the Form 14653 SFOP certification is now subject to greater scrutiny for HNW positions involving substantial private bank balances, due to the IRS LB&I’s refined review focus.
The IRS willfulness framework, as articulated in Bedrosian v United States (3rd Cir 2018) and Bittner v United States (US Supreme Court 2023), distinguishes between non-willful conduct (negligence, inadvertence, mistake-based, or rooted in good-faith misunderstanding) and willful conduct (voluntary, intentional violation of a known legal duty or willful blindness amounting to reckless disregard). The framework rejects ordinary negligence as insufficient to support willfulness, requiring a higher mental state.
For HNW private banking positions, several factual patterns push toward willful framing and require particularly careful diagnosis. Substantial private bank balances maintained over many years without reporting create initial concerns. A professional background in finance, law, or investment management raises questions about why cross-border tax obligations were not identified. Use of UK private banking, rather than retail banking, suggests sophisticated financial management with attendant tax awareness. Sustained patterns of account use combined with US connections raise concealment concerns. The IRS willfulness reference sits at https://www.irs.gov/irm/part4/irm_04-026-016.
Several factual patterns support non-willful framing for HNW positions. A demonstrable lack of awareness of citizenship-based US taxation is evident in cases of long-term UK residents who arrived as young adults with limited US connections, US-UK dual citizens born outside the US with one US parent, and accidental Americans who acquired citizenship through birthplace without active US ties. Reliance on UK-only private banking relationship managers who never asked about US obligations supports non-willful framing. Inheritance of accounts from UK-born parents, creating a sudden HNW position without prior cross-border tax exposure, supports non-willful framing.
The specialist diagnostic identifies which framing the specific facts support and drafts the Form 14653 narrative to address the strongest supportable position. For HNW positions in borderline cases, the diagnostic typically takes 4 to 8 weeks before any submission preparation begins. The integrated specialist approach also identifies whether the case should proceed under SFOP (non-willful) or the IRS Voluntary Disclosure Practice updated in 2018 (for willful cases with criminal protection requirements). The IRS Voluntary Disclosure Practice reference sits at https://www.irs.gov/compliance/criminal-investigation/voluntary-disclosure-practice.
The second core layer covers comprehensive private bank documentation collection and FBAR catch-up over 6 years. HNW private banking positions typically involve multiple sub-accounts within a single banking relationship, as well as multiple banking relationships across different UK private banks.
The documentation request to the UK private bank typically covers six years of consolidated statements showing all sub-accounts, including primary current accounts, deposit accounts, fixed-term savings accounts, foreign currency accounts (USD, EUR, CHF, and others), Lombard credit facility accounts, investment management portfolios with underlying holdings detail, and any other related accounts. UK private banks generally maintain comprehensive client records and respond to formal documentation requests within 4 to 6 weeks for HNW relationships, though some legacy records may require additional time.
Each FBAR covers all reportable foreign financial accounts where the aggregate balance exceeded $10,000 at any time during the calendar year. For HNW private banking positions, every sub-account within the private banking relationship typically requires separate FBAR reporting. A typical Coutts private banking relationship might include 8 to 15 sub-accounts each requiring FBAR coverage across six years of catch-up filings. The Bittner v United States per-report methodology means the FBAR penalty calculation runs per annual FBAR rather than per individual account. However, each account still requires accurate reporting within the FBAR.
The FBAR captures year-end balance and peak balance for each account, converted to USD using the Treasury Reporting Rates of Exchange year-end rate published at https://fiscal.treasury.gov/reports-statements/treasury-reporting-rates-exchange/. The identification of peak balances across six years for substantial private banking positions requires careful review of monthly statements to identify any mid-year balance peaks above year-end balances.
The catch-up FBARs through the BSA E-Filing System include the streamlined explanation reference per IRS guidance. The FBAR submission is filed separately from the Form 1040 submission, but the two are coordinated through the streamlined route reference. The FinCEN BSA E-Filing reference sits at https://www.fincen.gov/report-foreign-bank-and-financial-accounts.
The third core layer covers integrated Form 1040 preparation, including Form 8938 FATCA Statement of Specified Foreign Financial Assets and Schedule B foreign interest and dividend reporting. HNW private banking positions typically produce material US tax exposure across the three streamlined Form 1040 years that the catch-up preparation must capture accurately.
Form 8938 reporting under IRC Section 6038D applies to specified foreign financial assets above the threshold ($200,000 single year-end or $300,000 any time during year for unmarried foreign-resident filers; $400,000 single year-end or $600,000 any time during year for married joint foreign-resident filers). HNW private banking positions easily exceed these thresholds. Form 8938 captures account-level details, including the maximum value for the year, the account currency, the account opening date, and institution information.
Schedule B foreign interest and dividend reporting captures the underlying income from private banking accounts, including deposit interest on UK savings and fixed-term deposits, typically at 4 to 6 percent during 2022 to 2024, foreign currency account interest, and any UK-source dividend income from investment management portfolio holdings. The Schedule B Part III foreign accounts questions require accurate “yes ” responses confirming ownership of foreign financial accounts.
The Form 1116 Foreign Tax Credit absorbs UK income tax paid on the private banking income. For HNW positions, the UK Personal Savings Allowance of zero for additional rate taxpayers means substantial UK income tax exposure on the interest income, with the Foreign Tax Credit typically providing full absorption of US tax on the same income.
The investment management portfolio holdings within the private banking relationship require careful analysis for PFIC treatment under IRC Section 1297. UK-domiciled funds, investment trusts, and ETFs in the portfolio qualify as PFICs and are subject to Form 8621 reporting under IRC Section 1291, with an excess distribution tax. The portfolio review with the private banking investment manager identifies the holdings classification.
Engage Jungle Tax for a confidential initial diagnostic consultation. The consultation covers the willfulness framing analysis based on the specific factual circumstances, the SFOP eligibility confirmation through the 330-day foreign residency test, the comprehensive inventory of the private banking relationship and any other UK financial accounts, the broader cross-border position including any UK property and UK company interests, and the recommended route selection between SFOP, SDOP, Voluntary Disclosure Practice, and other available options. The diagnostic produces a written engagement letter setting out the proposed scope, fee, and timeline.
Document the private banking relationship comprehensively. Request six years of consolidated statements from the UK private bank covering all sub-accounts. The request should explicitly cover all current accounts, deposit accounts, fixed-term savings accounts, foreign currency accounts, Lombard credit facility accounts, investment management portfolios with underlying holdings detail, and any other related accounts. UK private banks typically respond within 4 to 6 weeks for HNW relationship documentation requests.
Run the PFIC analysis on any investment management portfolio holdings. UK-domiciled funds, investment trusts, and ETFs within the private banking investment management portfolio qualify as PFICs under IRC Section 1297, requiring Form 8621 reporting across each streamlined Form 1040 year. Coordinate with the private banking investment manager to identify the classification of each holding. The IRS PFIC reference sits at https://www.irs.gov/forms-pubs/about-form-8621.
Coordinate the PFIC remediation with the private banking investment manager. Where the investment management portfolio contains UK-domiciled holdings subject to PFIC treatment, coordinate their liquidation and reinvestment into US-domiciled alternatives accessible through international platforms. The remediation stops further PFIC accrual prospectively while the streamlined catch-up addresses the historic PFIC tax exposure.
Prepare three years of Form 1040 returns with comprehensive schedules and information returns. Each return captures worldwide income, including UK partnership distributions, UK employment income, UK rental income, UK investment income from the private banking position, US-source dividends, and capital gains from any US-domiciled holdings, and any other relevant income. The Form 1040 includes Schedule B, Schedule D, where applicable, Schedule E for rental and partnership income, Form 1116 Foreign Tax Credit, Form 8938 FATCA disclosure, Form 8621 for any PFIC positions, Form 5471 for any controlled foreign corporation interests, and Form 8833 treaty positioning where applicable.
Prepare six years of FBAR returns through the BSA E-Filing System. Each FBAR covers all reportable foreign financial accounts with year-end and peak balances converted to USD using the Treasury Reporting Rates of Exchange. The catch-up FBARs include the streamlined explanation reference per IRS guidance.
Draft the comprehensive Form 14653 non-willfulness narrative. The narrative addresses the specific factual circumstances supporting non-willful framing, including the timeline of awareness, the source of awareness, the reason for prior non-compliance, the specific professional and personal background factors, the relationship history with the UK private bank, and the immediate actions taken once aware. HNW private banking narratives require particular care, given the IRS LB&I refined review focus.
Mail the comprehensive submission package to the IRS Streamlined Filing Center in Austin, Texas. The package includes the three years of Form 1040 returns with all schedules and information returns, the Form 14653 certification, and the covering letter referencing the SFOP route. Payment of any underlying US tax plus statutory interest accompanies the package.
File the six FBARs through the BSA E-Filing System with the streamlined explanation reference. The FBAR submission is separate from the Form 1040 submission, but they coordinate through the streamlined route reference per IRS guidance.
Monitor post-submission and integrate with prospective compliance. Most HNW submissions are accepted without inquiry over 6-12 months. The post-streamlined, ongoing relationship continues with integrated annual compliance covering both the US and UK sides, plus strategic planning across the FA 2025 framework, US lifetime exemption positioning, and cross-border estate planning.
Case Study: An American Family Office Principal With £8.4 Million Coutts Private Banking Relationship
Elizabeth is a fictional but representative profile based on a typical Jungle Tax engagement. She is a US-UK dual citizen who moved to London in 2008 from New York to manage her late father’s UK property and investment holdings. She became the principal of the family office in 2012 after her father’s death, inheriting substantial UK assets that integrated with her existing UK position. By 2025, her family office position included a Coutts private banking relationship with a combined balance of approximately £8.4 million across primary current accounts, deposit accounts, foreign currency accounts in USD and EUR, a Lombard credit facility used for liquidity, and an investment management portfolio of approximately £6.2 million within the relationship. She also owned a London property in Belgravia, held in her sole name and valued at £6.8 million, plus a Cotswolds country house valued at £2.4 million. She held trustee positions on two family trusts.
Elizabeth had filed UK Self Assessment annually through her UK chartered accountancy firm in Mayfair at £18,000 annually, but had never filed a US tax return. She had assumed that her dual citizenship, combined with her UK residence and UK PAYE arrangements, covered all obligations. She received a FATCA letter from Coutts in early 2026, prompting her to seek specialist support. She engaged Jungle Tax for an integrated diagnostic and streamlined catch-up engagement.
Our diagnostic ran across two months with particular attention to the willfulness framing. Elizabeth’s circumstances supported non-willful framing through several factors. She had inherited her UK financial position rather than building it, with the substantial wealth originating from her father’s UK holdings rather than the concealment of US assets. Her US-UK dual citizenship, from birth to a US parent with limited subsequent US connections, supported a genuine lack of awareness of citizenship-based US taxation. Her UK-only adviser team had never raised US obligations, despite her dual citizenship being known. Her family office activities were entirely UK-focused with no US connection. The non-willful narrative was supportable on the specific facts.
The technical analysis identified material complexity. The Coutts investment management portfolio contained 18 UK-domiciled fund positions that required Form 8621 PFIC analysis under IRC Section 1297 across the three streamlined Form 1040 years, with approximately $48,400 in IRC Section 1291 tax. The London property generated rental income of approximately £165,000 annually, requiring Schedule E reporting across the three years. The Cotswolds property had been let on a short-term holiday let basis, generating approximately £42,000 annually. The two family trusts on which Elizabeth held trustee positions required Form 3520-A, the foreign trust information return, and Form 3520, the annual transactions return, under IRC Section 6048. The aggregate Form 8938 FATCA disclosure thresholds were comfortably exceeded.
The integrated streamlined catch-up was prepared over six months from February to August 2026. The PFIC remediation in March 2026 liquidated the UK-domiciled investment management portfolio holdings in coordination with the Coutts investment manager and reinvested in US-domiciled equivalents accessed through Saxo. The three years of Form 1040 returns captured worldwide income including the UK rental income with full Foreign Tax Credit absorption on Form 1116, the investment management portfolio dividend and interest income, the substantial private banking deposit interest, the Form 8621 PFIC reporting across 18 positions, the Form 3520 and Form 3520-A foreign trust reporting, the Form 8938 FATCA disclosure, and the Form 8833 treaty positioning where applicable.
The six years of FBARs through the BSA E-Filing System covered the Coutts primary current accounts, deposit accounts, foreign currency accounts, Lombard credit facility account, investment management portfolio account, and her separate Lloyds current account, which she had maintained before 2008. The comprehensive submission package was mailed to the IRS Streamlined Filing Center in Austin, Texas, in late August 2026.
The IRS acknowledged the submission without issuing a follow-up inquiry letter. The integrated outcome was net additional US tax of approximately $86,200 across three years (the PFIC tax of $48,400, plus net US tax on the rental income after Foreign Tax Credit of approximately $24,800, plus net US tax on investment income of approximately $13,000), zero FBAR penalty under 31 USC 5321 (avoided $775,000+ exposure under per-report Bittner methodology on the substantial private banking balances), zero failure-to-file penalty under IRC Section 6651, zero Form 8938 FATCA penalty under IRC Section 6038D (avoided $30,000+ exposure across three years), and clean US compliance going forward. Total Jungle Tax fees: £32,600 for the comprehensive streamlined engagement plus £8,400 for ongoing annual compliance setup.
Elizabeth’s reflection: “The Coutts FATCA letter was deeply concerning, given the scale of the position and my dual citizenship status. The integrated specialist diagnostic ran four weeks before submission preparation began, which felt slow but was completely justified. The work captured the technical complexity across PFIC, foreign trust reporting, and private banking documentation. The streamlined route eliminated potential penalty exposure that could have run into the millions for the cost of the genuine US tax owed plus the integrated specialist fee.” Speak to a Jungle Tax adviser today by emailing hello@jungletax.co.uk or visiting our offices for a confidential consultation.
Responding to FATCA letters from UK private banks before engaging specialist support. FATCA letters from UK private banks confirm that the bank has reported the account to HMRC under the US-UK FATCA Intergovernmental Agreement, with the information then passed to the IRS. Responding directly to the bank without specialist advice can create additional complications. The right response is to engage specialist support immediately rather than responding directly to the bank.
Underestimating the complexity of the willfulness framing analysis for HNW positions. The IRS LB&I refined review applies particular scrutiny to HNW submissions involving substantial private bank balances. Generic Form 14653 narratives unsupported by detailed factual analysis attract scrutiny and potential rejection. Specialist diagnostic and narrative drafting addressing the specific factual circumstances is materially more important for HNW positions than for standard expat streamlined work.
Missing the comprehensive FBAR coverage across all private banking sub-accounts. UK private banking relationships typically include multiple sub-accounts, each requiring separate FBAR reporting. The FBAR captures the year-end balance and peak balance for each account. Missing sub-accounts in the FBAR catch-up creates compliance gaps that can trigger IRS follow-up after the submission appears to be accepted.
Failing to coordinate the PFIC remediation with the private banking investment manager. UK-domiciled holdings in the private banking investment management portfolio qualify as PFICs under IRC Section 1297, subject to punitive treatment. The remediation requires coordination with the investment manager for liquidation and reinvestment in US-domiciled alternatives. The IRS PFIC reference sits at https://www.irs.gov/forms-pubs/about-form-8621.
Missing the Form 3520 and Form 3520-A foreign trust reporting, where applicable. HNW Americans with private banking relationships often hold trustee positions on UK family trusts or beneficiary interests in offshore trust structures. The reporting requirements under IRC Section 6048 are technical, and penalty exposure under IRC Section 6677 is material. The streamlined catch-up addresses these obligations alongside the underlying Form 1040 and FBAR work.
Treating the streamlined catch-up as a one-off rather than the start of an integrated ongoing relationship. Post-streamlining, ongoing compliance across both the US and UK requires the same integrated specialist capability. HNW positions benefit from continuous specialist relationships that cover annual compliance, monitoring of the FA 2025 framework, US lifetime exemption planning, and integration with the broader adviser team. The HMRC residence reference sits at https://www.gov.uk/guidance/residence-domicile-and-remittance-basis-of-taxation.
Jungle Tax is led by chartered tax advisers holding CTA status with the Chartered Institute of Taxation or ACCA professional accountancy status on the UK side, combined with IRS Enrolled Agent and US CPA credentials on the US side. The IRS Enrolled Agent credential under Circular 230 provides direct representation rights before the IRS for HNW streamlined submissions, including any follow-up examinations or appeals to the IRS Independent Office of Appeals.
Our HNW SFOP engagement covers the comprehensive eligibility diagnostic running 4 to 8 weeks for borderline cases, the willfulness framing analysis against the IRS framework as articulated in Bedrosian v United States and Bittner v United States, the comprehensive documentation gathering from the UK private bank covering six years of consolidated statements across all sub-accounts, the PFIC analysis and remediation coordination with the private banking investment manager, the controlled foreign corporation analysis for any UK company interests with GILTI optimisation through IRC Section 962 election, the foreign trust analysis under IRC Section 6048 with Form 3520 and Form 3520-A preparation where applicable, the integrated treaty positioning across multiple income streams, the three years of Form 1040 preparation with comprehensive schedules and information returns, the six years of FBARs through the BSA E-Filing System, the Form 14653 non-willfulness narrative drafted against the IRS willfulness framework with particular attention to the HNW LB&I refined review focus, the comprehensive submission package preparation and mailing, ongoing IRS correspondence handling, and the post-streamlined ongoing integrated annual compliance.
Speak to a Jungle Tax adviser today by emailing hello@jungletax.co.uk or calling 0333-8807974 to discuss your HNW private banking position confidentially.
Three takeaways. First, the Streamlined Foreign Filing Offshore Procedures framework provides the right catch-up route for HNW Americans with unreported UK private bank accounts where non-willful framing is supportable, with complete waiver of FBAR penalty under 31 USC 5321, Form 8938 FATCA penalty under IRC Section 6038D, Form 3520 foreign trust penalty under IRC Section 6677, and miscellaneous offshore penalty. Second, HNW private banking positions require integrated specialist capability covering high-stakes willfulness framing analysis, comprehensive private bank documentation across all sub-accounts, PFIC remediation coordination with the private banking investment manager, controlled foreign corporation analysis where applicable, and foreign trust reporting under IRC Section 6048. Third, the 2026 context, including FATCA enforcement maturity at UK private banks, including Coutts, Hoare, Drummonds, Cater Allen, and Weatherbys, the refined IRS LB&I review of HNW streamlined submissions, and the FA 2025 long-term residence framework, has substantially increased the time sensitivity and value of integrated HNW specialist support. Speak to a Jungle Tax adviser today by emailing hello@jungletax.co.uk or calling 0333-8807974.
Yes, provided the non-willful conduct standard under the Form 14653 SFOP certification is supportable on the specific facts. UK private bank accounts at Coutts, C. Hoare & Co, Drummonds, Cater Allen, Weatherbys, Adam & Company, and similar institutions are covered by the standard SFOP scope. The substantial balance does not disqualify the position, provided non-willful framing applies.
The non-willful FBAR penalty under 31 USC 5321(a)(5)(B) is up to $10,000 per report (inflation-adjusted to $129,210 in 2024 cases) with the Bittner v United States per-report methodology producing $60,000 to $775,000+ exposure across six years. The willful penalty under 31 USC 5321(a)(5)(C) is up to the greater of $100,000, inflation-adjusted, or 50 percent of the account balance per violation, potentially reaching several million dollars on HNW private banking balances.
The IRS willfulness framework, as articulated in Bedrosian v United States (3rd Cir 2018) applies the same non-willful versus willful standard to all taxpayers, but the IRS LB&I refined review applies particular scrutiny to HNW submissions. Specific factors supporting non-willful framing include a genuine lack of awareness of citizenship-based US taxation, reliance on UK-only advisers, inheritance creating sudden HNW position, and immediate action once aware. The IRS willfulness reference sits at https://www.irs.gov/irm/part4/irm_04-026-016.
HNW SFOP engagements typically run six to nine months from initial diagnostic through final IRS submission. The complexity factors, including extended willfulness framing (diagnostic of 4 to 8 weeks), comprehensive private banking documentation gathering (4 to 6 weeks), PFIC analysis across substantial investment management portfolios, foreign trust reporting, where applicable, and the comprehensive Form 1040 preparation, extend timelines compared with standard expat streamlined work.
HNW SFOP engagements typically run £20,000 to £45,000, depending on complexity. The scope covers extended diagnostic, comprehensive documentation gathering, PFIC remediation coordination, foreign trust reporting where applicable, controlled foreign corporation analysis where applicable, comprehensive Form 1040 and FBAR preparation, Form 14653 narrative drafting, and IRS submission management. The fee captures value materially exceeding the cost through avoided penalty exposure typically in the hundreds of thousands to millions of dollars.
Yes. UK private banks including Coutts, C. Hoare & Co, Drummonds, Cater Allen, Weatherbys, and Adam & Company, comply with the US-UK FATCA Intergovernmental Agreement and report US person account holders to HMRC for transmission to the IRS. The reporting includes account balances, account holder identification, and transaction summaries. The IRS FATCA reference sits at https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca.
