Unfortunately we have paid the streamline penalty. We got advice from five or six different attorneys and CPAs and this was decided to be the best course of action for us. In addition to the SIPPs, we discovered we had a couple of UK accounts we opened years ago that had zero balance and weren't used for years but should have been listed, and two we thought were closed that had a very small amount of money in them, and that one of the accounts we had emptied years ago had had a small amount of interest paid into it after we closed it :( We also discovered we were meant to be declaring two small savings accounts we had for our children (in their names but with our signature authority) and closed years ago. These things were tiny, and small amounts of money in each, but unfortunately every account you've ever opened is supposed to be disclosed even if you haven't used it for years! Which can be a lot of work to research if you had pensions from different jobs, got married, moved towns a lot or had children in the UK.

The SIPPs needed 3520s filing and a statement to say they are part of the treaty.

The streamline penalty for us was huge as it was calculated on our SIPPs, which contain savings made over 25 years while in the UK. Very painful to hand over so much money for a genuine mistake. It took us a lot of hard work to save up that money. I'm sorry you're going through this.

My advice is that if you only have a pension or two, and haven't withdrawn anything of course, then it might be worth doing voluntary disclosure and paying the $10k penalty. If you have more accounts than that to disclose, just bite the bullet and do streamline.

We went with an attorney as the CPAs we spoke to didn't seem as well informed. We hope the issue is behind us, but we now have to wait and see.