Can I use streamlined foreign offshore if I moved abroad part-way through a year?
The route is for filers living abroad, so eligibility is tested year by year rather than once for the whole period. A year in which you were outside the United States throughout sits differently from the year you left, and the covered years may not all qualify on the same basis. We establish residence and presence for each year from documents — entry and exit records, leases, employment contracts — before any return is prepared, because the eligibility finding is what everything else rests on. Where a year does not meet the test, it is far better to know at the outset than to discover it after filing.
Is it better to just file the missing returns and say nothing?
An ordinary late filing is still a filing, and it can close a catch-up route that was open the day before. These routes exist only while the disclosure is still voluntary, so the sequence matters more than speed: eligibility is assessed first, then the returns and account reports are prepared to match that assessment, then the certification is signed last. Filing first and deciding afterwards reverses that order and gives away the part you cannot get back.
Do I need to explain why I did not file, or just send the returns?
The returns and the account reports are the arithmetic; the signed non-willfulness certification is the substance. It sets out what you knew, when you knew it, and what you did once you knew — and it has to sit consistently beside every figure in the submission. A certification that reads well but contradicts the returns is the thing that turns relief into an examination, so in practice the narrative and the numbers are drafted together rather than one after the other.
I reported all my income but never filed the account reports — what now?
That is a materially different position from one where income was left out, and it is worth establishing which of the two you are in before anything is filed. Where the income was reported and the gap is the account reports alone, the facts to assemble are the accounts, their values through each year, and why the reports were missed. Where income was omitted as well, the returns themselves have to be corrected and the narrative has to account for both. The assessment is the same exercise either way, but the filing it leads to is not.
Who signs the non-willfulness certification, me or my accountant?
You sign it. It is your account of your own conduct, which is why it cannot be drafted as boilerplate and handed over for signature. Our part is to establish the chronology from documents, to ask the questions a reviewer will ask, and to make sure nothing in the narrative is contradicted by the returns or the account reports going with it. Where you relied on advice, that reliance is described as it happened, with dates, rather than simply asserted.
Can I still use the route if the IRS has already written to me?
Possibly not, and that is the first thing to settle. These routes stay open only while the disclosure is voluntary, so the arrival of a notice or the opening of an examination can be the event that closes one. Bring the correspondence to the first conversation in date order, including anything a bank has sent you about your tax residence or your accounts. What the letter actually asks for often decides which route remains, and filing into one that has already closed makes the position worse.
Are foreign trusts taxable in Canada?
They can be. Canada's deemed-resident-trust rules can pull a non-resident trust into the Canadian tax system where there is a resident contributor or, in some cases, a resident beneficiary — taxing it as though it were resident here. Separate reporting applies to transfers or loans to a non-resident trust and to distributions and debts from one. The planning point is that contributing to an offshore trust from Canada rarely achieves what the brochure suggests. See non-resident trusts.
Is moving money between my own accounts in two countries taxable?
Moving your own capital between your own accounts is not itself income, so the transfer is not what creates tax. What can create tax or reporting is the income the money earned before it moved, a foreign-exchange gain on certain holdings, and the reporting obligations the balances themselves trigger — foreign account and asset reports keyed to balances rather than income. Remittances out of some countries also need certification before the bank will send them. See foreign account reporting.
