Yes, under the Streamlined Filing Compliance Procedures, taxpayers are required to amend previously filed tax returns if those returns were inaccurate or incomplete in regard to foreign income and foreign assets. This is a key component of both the Streamlined Foreign Offshore Procedures and the Streamlined Domestic Offshore Procedures. The process involves submitting amended tax returns for the most recent three years for which the U.S. tax return due date (or properly applied for an extension) has passed.
For both procedures, taxpayers must also file delinquent FBARs (Foreign Bank and Financial Accounts Reports) for the last six years if they have not been filed or were filed incorrectly. The submission of these amended returns and FBARs, along with the payment of any taxes and interest due (and the miscellaneous offshore penalty under the Domestic Procedures), allows taxpayers to come into compliance with U.S. tax laws while potentially avoiding the harsher penalties that could apply outside of these streamlined processes.