Do I need a tax attorney to use the Streamlined Filing Procedures?
A tax attorney is not required to use the Streamlined Filing Compliance Procedures. An experienced expat CPA or Enrolled Agent handles most non-willful Streamlined cases. A tax attorney becomes important when willfulness is in question, when facts are ambiguous, or when the Voluntary Disclosure Practice might apply instead.
When a CPA or EA is sufficient:
- Clearly non-willful fact pattern
- Moderate balance of foreign accounts
- Clean certification is straightforward
- No criminal risk indicators
When a tax attorney is advisable:
- Willfulness is unclear or possible
- Very high account balances
- Complex structures (CFCs,PFICs, trusts) with compliance gaps
- Prior IRS contact or audit history
- Multiple years of active concealment
What attorneys add:
| Value | Why |
| Attorney-client privilege | Discussions protected from the IRS |
| Willfulness opinion | Independent counsel analysis |
| VDP navigation | If Streamlined is the wrong path |
| Audit representation | If the case converts to an audit |
Typical engagement models:
- CPA/EA only: Streamlined prep and filing
- Kovel arrangement: Attorney engages CPA for privileged return prep
- Joint representation: Attorney and CPA coordinate on complex files
Cost considerations:
- CPA/EA engagement typically costs $2,500 to $10,000 for a full Streamlined
- Attorney engagement adds $5,000 to $25,000 or more, depending on complexity
- Greenback’s flat-fee Streamlined Filing Package ($1,750) covers three years of delinquent federal returns, six years of FBARs, Form 14653 certification, and a dedicated expat tax accountant to maximize your exclusions and credits.
For Streamlined preparation help, see our Streamlined Filing Compliance Procedures guide.
Last updated on April 29, 2026
