Table of Contents
About the Author
By James J. Grennen, MBA, CFP, EA, CTRS
Last Updated: May 2026
Reviewed for IRS Tax-Resolution Accuracy
About the Author: James J. Grennen, MBA, CFP, EA, CTRS, is the founder of Long Island Tax Resolution Services. He works with taxpayers facing IRS and state tax problems, including unfiled returns, foreign account reporting issues, IRS notices, payment plans, penalty matters, and collection concerns. His practice focuses on helping taxpayers understand their options and choose a practical resolution path.
Disclaimer: This post is educational only and is not a substitute for personalized legal, tax, or financial advice. If you have unfiled U.S. returns, missed FBARs, IRS notices, or unpaid tax balances while living abroad, have your facts reviewed by a qualified tax professional before deciding what to file or how to respond.
If you are a U.S. citizen or green card holder living in Ireland and you have not filed U.S. tax returns for several years, the most important step is not to panic — and not to file old returns unthinkingly.
Many Americans in Ireland discover the problem late. They may have paid Irish tax for years, worked only for an Irish employer, and assumed their U.S. filing obligation ended when they moved abroad. Others knew they were behind but were unsure where to start.
By the time the issue comes to light, it may involve more than just old Form 1040 returns. Irish bank accounts, missed FBARs, Form 8938, IRS notices, penalties, interest, or unpaid balances may also need review.
Many expats can get back into compliance, but the filing path should match the facts.
For some taxpayers, the IRS Streamlined Foreign Offshore Procedures may be the right path. For others, delinquent FBAR procedures, late-filed returns, payment arrangements, penalty review, or a broader tax-resolution strategy may be needed. The best answer depends on your facts.
If you are catching up from Ireland, the question is not only which old returns are missing. You also need to know whether Irish bank accounts, missed FBARs, IRS notices, or unpaid balances change the safest way to proceed.
Quick Answer: What Should You Do if You Haven’t Filed U.S. Taxes in Years While Living in Ireland?
If you are years behind on U.S. tax filings while living in Ireland, first identify the full scope of the problem before sending anything to the IRS. The right path may involve Streamlined Filing, delinquent FBAR filings, ordinary late tax returns, or a broader tax-resolution strategy if IRS notices, unpaid balances, or collection issues are involved.
You need to know:
- Which U.S. tax years are missing
- Irish wages, self-employment income, rental income, pension income, or investment income
- Irish bank accounts or other foreign financial accounts that may have crossed the FBAR threshold
- Possible Form 8938 filing requirements
- Any IRS notices, letters, or prior contact
- The reason the U.S. returns were not filed
- Any U.S. tax, penalties, or interest that may be owed
- Your ability to pay if the catch-up filings show a balance due
The right catch-up path depends on what the review shows:
Your situation | Possible path to review | |
Missing U.S. tax returns and Irish bank accounts | Streamlined Foreign Offshore Procedures | |
U.S. returns were filed, but FBARs were missed | Delinquent FBAR Submission Procedures | |
The IRS has already sent a notice or letter | Professional review before choosing Streamlined Filing | |
Late returns show a balance you cannot pay | IRS payment plan, penalty review, or hardship-based collection option | |
The reason for non-filing may need explanation | Non-willful certification review or legal/tax-resolution guidance | |
Foreign assets, pensions, or investments are involved | Form 8938, FBAR, and international reporting review | |
That review matters because not every late-filing case belongs in the same bucket.
A taxpayer who missed three years of returns and had ordinary Irish PAYE income may need a different strategy than someone who had unreported self-employment income, several foreign accounts, missed FBARs, and an IRS notice already sitting unopened. A person who misunderstood the rules may be in a different position from someone who deliberately avoided reporting foreign income.
Before filing old returns, it is worth asking a better question:
Which IRS compliance path is safest for my facts?
The goal is to determine the safest IRS compliance route before submitting filings, not simply to prepare forms after the fact.
That is where professional tax-resolution guidance can make a meaningful difference.
Do Americans Living in Ireland Still Have to File U.S. Tax Returns?
In many cases, yes.
U.S. citizens and resident aliens are generally taxed on worldwide income, even if they live outside the United States. That means moving to Ireland does not automatically end the obligation to file a U.S. income tax return.
That rule catches many expats off guard. After several years in Ireland, especially with Irish PAYE tax already withheld, it is natural to assume the U.S. filing obligation faded into the background. But for U.S. citizens and green card holders, the filing question does not depend only on where they live or where they pay local tax.
If you are a U.S. citizen or green card holder, your filing requirement generally depends on your income, filing status, age, and other tax facts. Irish employment income, self-employment income, rental income, pension income, investment income, and certain other foreign income items may still need to be reported on a U.S. return.
The return is filed in U.S. dollars, not euros. That means income, taxes paid, deductions, and account values may need to be converted using appropriate exchange-rate methods.
This does not always mean you will owe U.S. tax. Many Americans in Ireland reduce or eliminate U.S. income tax through foreign tax credits, the foreign earned income exclusion, or other rules. But “I may not owe” is not the same as “I do not have to file.”
That distinction is where many expat tax problems begin.
“I Already Pay Tax in Ireland” — Why That May Not Be Enough
Paying Irish tax matters, but it does not automatically close the U.S. filing issue. In some cases, Irish income tax paid may reduce U.S. tax through the foreign tax credit. Some taxpayers may be eligible for the foreign earned income exclusion. Others may use a combination of reporting positions depending on their income, filing status, and facts.
But paying Irish tax does not automatically erase the U.S. filing requirement.
For example, an American working in Ireland may have tax withheld under the Irish PAYE system. That person may still need to file a U.S. tax return to report the income and claim the proper U.S. tax treatment. A self-employed American in Ireland may face additional complications, as self-employment income can raise different questions than wages. A person with Irish bank accounts may have separate FBAR obligations even if no U.S. income tax is ultimately owed.
This is one reason filing old returns without a plan can be risky. A taxpayer might focus only on the income tax return and miss the foreign account reporting issue. Or they might file late returns without realizing that a Streamlined submission, delinquent FBAR procedure, or other compliance path should have been considered first.
The goal is not just to file something. The goal is to file correctly, explain the situation where required, and avoid creating a larger IRS problem.
First, Find Out What Type of U.S. Tax Problem You Actually Have
Not every American in Ireland who is behind on U.S. taxes has the same problem. Before choosing a filing path, it helps to identify which problem you are actually trying to fix.
You Never Filed U.S. Tax Returns After Moving to Ireland
This is common. Someone moves to Ireland, starts working, pays Irish tax, and assumes U.S. filing is no longer required. Years pass. Then a bank, an accountant, an online article, a mortgage application, an inheritance issue, or an IRS notice brings the problem to the surface.
In this situation, the first review should identify:
- How many tax years are missing
- Whether income was high enough to require a U.S. return
- Whether income was wages, self-employment, pension, rental, or investment income
- If Irish tax was paid
- Whether foreign tax credits or the foreign earned income exclusion may apply
- Any missed foreign account reporting, including FBAR
- Potential eligibility for the Streamlined Foreign Offshore Procedures
The main mistake is assuming the only task is preparing several old tax returns. If foreign accounts were involved, the case may be more complicated.
You Filed U.S. Returns but Never Filed FBARs
Some expats have filed U.S. tax returns but were unaware of the FBAR requirement. Others used a tax preparer who did not ask enough questions about Irish accounts. In Ireland, common accounts that may need review include current accounts, savings accounts, credit union accounts, Revolut or similar accounts, brokerage accounts, and certain accounts where the taxpayer has signature authority.
FBAR is not filed with the regular federal tax return. It is a separate foreign account report. A taxpayer can owe no U.S. tax and still have an FBAR problem.
If the only issue is missed FBARs, delinquent FBAR submission procedures may be available in some cases. But that path is not for everyone. If income from the accounts was not properly reported, or if the IRS has already contacted the taxpayer, the analysis changes.
You Received an IRS Notice
An IRS notice changes the urgency level. Do not assume that living in Ireland gives you extra time to ignore the issue.
IRS notices sent to a foreign address may arrive late, be misunderstood, or get lost during a move. But deadlines can still matter. A notice may involve missing returns, a balance due, proposed changes, penalties, identity verification, foreign account issues, or collection action.
The notice date, response deadline, and tax year involved should be checked before deciding the next step.
If the IRS has already contacted you about delinquent returns, FBARs, or an examination, do not assume that Streamlined Filing is still available without review. The notice should be read carefully, and transcripts may be needed to see what the IRS has on record.
Practical note: For taxpayers living abroad, the first issue is often timing. The notice may have been mailed weeks earlier, so the notice date and response deadline should be checked before deciding whether the issue is still routine or already moving toward collection.
You Owe U.S. Tax and Cannot Pay
Catching up on filings and resolving a balance due are related, but they are not the same thing.
A taxpayer may need to file missing returns first so the IRS has accurate balances. After that, the focus may shift to collection resolution. Depending on the facts, options may include an installment agreement, penalty review, Currently Not Collectible status, or another resolution strategy.
From Ireland, even a basic IRS payment arrangement can involve practical issues such as foreign banking limits, currency conversion, delayed mail, and time-zone problems when contacting the IRS.
You Are Worried the IRS May View the Non-Filing as Intentional
This is one of the most important issues.
Streamlined Filing is generally available only when the taxpayer’s failure to disclose foreign financial assets or pay related tax was not intentional. Non-willful conduct usually refers to a mistake, oversight, negligence, or an honest misunderstanding of the filing and reporting requirements.
That sounds straightforward, but the facts matter.
A taxpayer who never heard of FBAR and believed Irish tax compliance was enough may have a very different risk profile from someone who knew about the rules, moved funds between accounts, ignored prior advice, or deliberately avoided reporting foreign income.
The non-willful certification is not a casual formality. It is often the heart of a Streamlined submission. It should be accurate, specific, and consistent with the taxpayer’s records.
IRS Catch-Up Options for U.S. Expats in Ireland
Americans in Ireland who are behind on U.S. tax filings may have more than one way to get back into compliance. A simple missed-return case is different from one involving Irish bank accounts, IRS letters, unpaid balances, self-employment income, or questions about why the filings were missed.
Option 1: Streamlined Foreign Offshore Procedures
The Streamlined Foreign Offshore Procedures are often the first option people hear about. For eligible taxpayers living outside the United States, the streamlined process generally involves filing the most recent 3 years of delinquent or amended U.S. tax returns and, if required, 6 years of FBARs.
This procedure can be valuable for Americans in Ireland who failed to file because they misunderstood the rules, made incorrect assumptions, or did not know that foreign accounts must be reported.
A Streamlined submission generally includes:
- Three years of delinquent or amended federal tax returns
- Six years of delinquent FBARs, if required
- Payment of tax and interest due, if any
- A signed non-willful certification explaining why the taxpayer failed to comply
The non-willful certification is one part of the Streamlined submission that should be handled with care. It should explain the facts in plain language, including how the taxpayer came to live in Ireland, why they believed they were meeting their tax obligations, how the missed U.S. filing issue came to light, and what they did once they understood the problem.
A Streamlined submission should be treated as a serious compliance position, not a routine filing package. When done poorly, it can leave the taxpayer exposed.
Taxpayers should also understand that a Streamlined submission is not the same as receiving a closing agreement from the IRS. The returns are generally processed like other returns, and the IRS does not automatically provide a formal closing document confirming that every issue is resolved.
Example: A U.S. citizen who had lived in Ireland for several years worked under PAYE, paid Irish tax, and kept ordinary Irish bank and credit union accounts. The taxpayer had not filed U.S. returns or FBARs because they believed Irish tax compliance was enough. In a case like this, the review would usually begin with missing U.S. tax years, Irish tax paid, FBAR thresholds, Form 8938 exposure, IRS contact history, and whether the facts support a non-willful Streamlined submission.
Option 2: Delinquent FBAR Submission Procedures
Some taxpayers filed their U.S. tax returns and paid all tax due, but failed to file FBARs for Irish accounts. In that narrower situation, delinquent FBAR submission procedures may be an option.
This is not the same as Streamlined Filing.
Delinquent FBAR procedures may apply to taxpayers who properly reported and paid tax on income from foreign financial accounts, were not contacted by the IRS about the issue, and are not under examination or criminal investigation. The late FBARs are filed electronically, and an explanation is provided.
This option can be useful, but it should not be used casually. If the taxpayer also failed to report income, failed to file returns, or received an IRS contact, the case may require a different approach.
Option 3: Filing Delinquent Tax Returns Outside Streamlined
Streamlined Filing is not the right fit for every taxpayer with missing returns. In some cases, the better approach is to prepare and file the missing U.S. tax returns under the normal late-filing process.
This may apply where there is no foreign account issue, the taxpayer does not meet the Streamlined requirements, or the facts point to another strategy.
However, filing old returns without considering foreign account reporting can be a mistake. A late-filed Form 1040 may answer one problem while leaving FBAR, Form 8938, or other international reporting issues unresolved.
The order of operations matters. Before filing, the taxpayer should understand the full extent of their exposure.
Option 4: Voluntary Disclosure or Legal Review for Higher-Risk Cases
Some cases require more caution.
If the taxpayer knowingly concealed foreign income or accounts, ignored prior professional advice, made false statements on prior returns, or has facts that suggest willfulness, Streamlined Filing may not be safe.
These cases should be reviewed carefully before any filings are made. In higher-risk situations, legal counsel may be required. The point is not to frighten taxpayers. The point is to avoid using a non-willful procedure when the facts do not support it.
Taking the wrong path can create more risk than pausing long enough to review the facts properly.
Ireland-Specific Issues That Can Complicate Catching Up on U.S. Taxes
A strong catch-up plan should account for how life in Ireland actually works. A generic expat tax checklist may miss important details.
Irish PAYE Employment Income
Many Americans in Ireland have tax taken from their wages through the PAYE system, so it is easy to think the matter is already handled. That can be true for Irish tax, but it does not automatically answer the U.S. reporting question.
Irish wages may still need to be reported on a U.S. return. The taxpayer may need to determine whether U.S. tax can be reduced through foreign tax credits, the foreign earned income exclusion, or both. The correct approach depends on the numbers, the taxpayer’s residency facts, and the overall return.
Irish Self-Employment Income
Self-employed Americans in Ireland often have more to sort through than wage employees. Income from consulting, contract work, freelancing, directorships, or sole-trader activity may be properly reported in Ireland, but it should still be reviewed for U.S. tax purposes.
Self-employment cases can raise questions about income reporting, deductions, foreign tax credits, social security coverage, and treaty or totalization issues. These cases should not be treated as simple wage-earner catch-up cases.
Irish Bank Accounts and FBAR
FBAR mistakes are common because the threshold is easy to misunderstand.
The FBAR threshold is not based on a single account. It is based on the aggregate value of foreign financial accounts. A taxpayer with several ordinary Irish accounts can cross the threshold even if no single account feels large. The FBAR reporting threshold is $10,000 or more in aggregate foreign financial accounts at any point during the calendar year. It is not based only on the year-end balance.
Accounts to review may include:
- Irish current accounts
- Irish savings accounts
- Credit union accounts
- Revolut or similar financial accounts
- Brokerage accounts
- Certain pension or investment accounts
- Joint accounts with a spouse
- Accounts where the taxpayer has signature authority
A taxpayer who says, “It was just my normal Irish checking account,” may still have a reporting issue.
Irish Pensions, Investments, and Foreign Assets
Irish pensions and investment accounts can require closer review. The U.S. treatment may differ from the Irish treatment, and these accounts should be reviewed before assuming they are treated the same way for U.S. tax purposes. Some accounts may create income tax reporting issues, foreign asset reporting issues, or both.
Form 8938 may also apply if specified foreign financial assets exceed the applicable threshold. Form 8938 is separate from FBAR, and some taxpayers may need both.
This is why a catch-up plan should include more than wage income. It should review accounts and assets annually.
Currency Conversion and Missing Records
U.S. tax returns are prepared in U.S. dollars. For taxpayers in Ireland, that means that euro income, Irish tax paid, account balances, and other figures may need to be converted.
After several years, gathering the records can take some work. Older bank statements may no longer be available online; employers may need to pull past payroll details; and self-employed taxpayers may need to piece together income and expenses from invoices, deposits, Irish tax records, and any remaining business documents.
Missing records are common. They are not a reason to ignore the issue. But they do need to be handled carefully.
FBAR vs. Form 8938: Why Americans in Ireland Often Confuse Them
FBAR and Form 8938 are two different reporting obligations. They overlap, but they are not the same.
What Is FBAR?
FBAR is the common name for the Report of Foreign Bank and Financial Accounts. It is filed electronically with FinCEN, not attached to the regular federal income tax return.
A U.S. person may have an FBAR filing requirement if they own, control, or have signing authority over foreign financial accounts and the combined value of those accounts exceeds the reporting threshold at any point during the year.
For Americans in Ireland, this can include ordinary local accounts. It is not limited to tax shelters or offshore investment structures.
What Is Form 8938?
Form 8938 is used to report specific foreign financial assets on the federal tax return when necessary. For U.S. expats in Ireland, it may apply when foreign accounts, investments, or other financial assets exceed the applicable thresholds. It is separate from FBAR, and the rules differ.
A taxpayer living abroad may have higher Form 8938 thresholds than a taxpayer living in the United States, but that does not mean the form can be ignored. If the taxpayer has significant Irish or other foreign assets, Form 8938 should be reviewed.
Why Missing FBARs Can Be Serious Even if No U.S. Tax Is Owed
This is one of the most important points for expats.
A person can owe no U.S. income tax and still have a foreign account reporting problem. That is because FBAR is not based on whether tax is owed. It is based on foreign account ownership, signature authority, and account values.
That is why the phrase “I paid tax in Ireland” does not answer the question in its entirety. It may help with income tax, but it does not automatically fix FBAR.
What if You Owe U.S. Tax, Penalties, or Interest After Catching Up?
Some Americans in Ireland are relieved to learn they owe little or no U.S. tax after credits or exclusions. Others are not so lucky. They may owe tax, penalties, and interest for one or more years.
If a balance is due, the case shifts from compliance into tax resolution.
IRS Payment Plans for Expats
If you owe the IRS and cannot pay the full balance in one lump sum, a payment plan may be available. To keep that arrangement in good standing, you generally need to file future returns on time and make the required payments.
For expats, the mechanics can be harder. Payment methods, foreign bank accounts, currency conversion, and communication with the IRS can complicate the process. The agreement should be realistic. A payment plan that fails after a few months can create more problems.
Penalty Review and Possible Penalty Relief
Late filing, late payment, accuracy issues, information return issues, and foreign account reporting issues can all create penalty exposure.
Not every penalty can be removed. But some cases may support penalty relief. The argument depends on the type of penalty, the taxpayer’s history, the reason for noncompliance, the records available, and whether the taxpayer acted promptly after discovering the issue.
A strong penalty review should be fact-specific. Generic explanations rarely help.
Currently Not Collectible Status for Financial Hardship
Currently Not Collectible may be an option when the taxpayer’s financial records show that monthly IRS payments are not realistic. It does not remove the balance, and penalties and interest may continue to grow. The benefit is that the IRS may pause active collection while the taxpayer remains in financial hardship.
For an IRS hardship request to move forward, the missing-return issue must usually be addressed first. The IRS will also look closely at the taxpayer’s financial picture, including monthly income, necessary expenses, account balances, assets, and available cash. For a U.S. expat in Ireland, that review may include Irish wages or business income, rent or mortgage costs, euro-to-dollar conversion, Irish bank accounts, and other foreign assets that affect the taxpayer’s ability to pay.
IRS Notices, Liens, Levies, and Passport Risk
An IRS balance can continue to create problems even when the taxpayer lives in Ireland. Notices may be sent to the last address the IRS has on file, and delays with international mail can make it easier to miss an important deadline.
If the balance remains unresolved, penalties and interest may continue to increase. The IRS may also move the account into collection after the required notice process. That can include a federal tax lien, a levy, or other collection action, depending on the facts of the case.
Passport risk is another issue for U.S. expats to review. A seriously delinquent federal tax debt can, in certain cases, be certified to the State Department. For an American living in Ireland, a passport problem can affect travel, work, family responsibilities, and residency-related matters.
Passport action becomes a concern only when the IRS has moved the account into the seriously delinquent tax debt category and the legal requirements for certification are met. A taxpayer who sets up an accepted payment plan, qualifies for hardship status, or resolves the account through another recognized IRS option may be able to avoid that certification or have it reversed.
A taxpayer does not need to wait for the IRS to take stronger action. Once there are missed filings, unpaid balances, or IRS notices, the better approach is to review the account and choose a resolution path before the case becomes more difficult to manage.
When You Should Get Professional Tax Resolution Help Before Filing
Some taxpayers can handle simple late-filing issues on their own. But many expat cases are not simple.
You should consider professional tax-resolution help before filing if:
- U.S. tax returns have been missing for more than three years
- Irish bank, credit union, brokerage, or investment accounts may have exceeded the FBAR threshold
- An IRS notice has already arrived
- A U.S. tax balance is due, and full payment is not affordable
- The reason for the missed filings is unclear or may need a non-willful explanation
- Self-employment income was earned in Ireland
- Rental property was owned or reported in Ireland
- Irish pension, investment, or foreign asset reporting questions are involved
- Some U.S. tax years were filed, but others were missed
- Late forms were previously submitted without a clear IRS compliance strategy
- Penalties, liens, levies, collection action, or passport risk are a concern
The more complicated your facts, the more important it is to slow down before filing. The IRS may offer paths back into compliance, but those paths have rules. Choosing the wrong one can make the situation harder to fix.
How Long Island Tax Resolution Services Helps U.S. Expats in Ireland
Long Island Tax Resolution Services helps taxpayers who need more than routine tax preparation. For Americans in Ireland who are years behind, the question is often not simply, “Which forms do I file?”
The better question is:
Which IRS compliance path is safest for my facts?
LITRS can help review the issues that matter before filings are submitted, including:
- Missing U.S. tax years
- IRS transcript history
- Streamlined Filing eligibility
- FBAR exposure
- Form 8938 concerns
- IRS notices
- Penalty risk
- Tax balances and interest
- Payment options
- Collection concerns
- Passport certification risk
For many Americans in Ireland, the situation becomes easier to manage once the facts are laid out clearly. After the missing tax years, foreign account reporting, IRS correspondence, and possible balances are reviewed, the taxpayer can choose a compliance path rather than filing in a hurry or letting the problem go unresolved.
Why the Right Catch-Up Path Matters
The IRS catch-up process should fit the facts. A simple misunderstanding about U.S. filing rules is not the same as a case involving IRS notices, unpaid balances, unreported account income, or possible non-willfulness concerns.
That distinction can affect what should be filed, how late filings should be explained, and whether penalties or collection issues should be handled at the same time.
The purpose of this review is not to make the situation sound more serious than it is. It is to make sure a taxpayer does not use a filing method that fails to address the real IRS problem. When several years are missing, the way the taxpayer returns to compliance can matter almost as much as the filings themselves.
Frequently Asked Questions
Final Thought
A long gap in U.S. tax filing can feel overwhelming, especially when your life and finances are now based in Ireland. But the problem should not be handled by guessing, filing whatever forms seem overdue, or assuming that Irish tax filings have addressed the U.S. side.
A careful review should come before any late filing. The taxpayer should first confirm the missing U.S. tax years, look at Irish bank and investment accounts for possible FBAR or Form 8938 reporting, and check the IRS account for notices, balances, or collection activity. After that, the available route may be Streamlined Filing, delinquent FBAR filing, regular late returns, or a separate plan for penalties and unpaid tax.
Long Island Tax Resolution Services helps U.S. taxpayers in Ireland sort through those issues before filings are submitted, so the catch-up process is handled with a clear IRS compliance strategy.