Do I still have to file a U.S. tax return abroad even if the IRS has never contacted me?

Yes. U.S. citizens and green-card holders file based on worldwide income, not on whether the IRS has contacted them. If your income is below the filing threshold, you may not need to file a return, but foreign accounts over $10,000 combined still require an FBAR. Form 8938 is different: it is filed only with a tax return, so if you have no return to file, you do not file Form 8938. Streamlined Filing Compliance Procedures are designed for this exact situation.

Why silence is not safety:

• Citizen-based taxation: U.S. obligation follows passport and green card
• FATCA data exchange: Foreign banks report U.S. accounts to the IRS annually
• Treaty/CRS exchange: Broadens the reach further
• Statute of limitations: Remains open indefinitely on unfiled returns

Consequences of waiting until contacted:

• Loss of Streamlined eligibility
• Higher willful-type penalties potentially applicable
• Passport revocation for seriously delinquent debt (over $65,000 inflation-adjusted)
• Criminal exposure in severe cases

When the IRS typically learns:

Getting current:

• Streamlined Foreign Offshore: 3 years of returns, 6 FBARs
• Delinquent FBAR Submission: FBAR only, no tax owed
• Delinquent International Info Return Submission: 5471/3520 only, no tax owed

For expat catch-up help, see Streamlined Filing Compliance Procedures.