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Delinquent U.S. Taxpayers in Southeast Asia

Quick Summary: U.S. Tax Obligations for Americans in Southeast Asia

Question Answer
Do U.S. citizens living in Vietnam or the Philippines need to file U.S. taxes? Yes, regardless of where in the world they live
Legal basis? Printed on the last page of every U.S. passport: all U.S. citizens abroad must file and report worldwide income
Income filing threshold for 2025 (single filer)? Worldwide income exceeding $14,600
Can you skip filing if income is below the threshold? Possibly, but filing is still recommended to prove compliance to IRS
Consequences of late filing? Penalties, interest, and impact on family sponsorship and citizenship renunciation
How to fix delinquency? File missing returns immediately or join the IRS SFOP amnesty program
Who can help in Vietnam and the Philippines? Arancel Consulting, tax partner of Enterline and Partners

While living in the Southeast Asian region, it’s easy to forget about U.S. tax obligations, especially if the taxpayer’s income is deemed “minimal.”  Let’s first re-visit our tax filing requirements, where an excerpt is noted right on the last page of one’s U.S. Passport, “All U.S. Citizens working and residing abroad are required to file and report on their worldwide income. (Valium online) Consult IRS Publication 54 …”

Tax practitioners may use the standard deduction as the filing threshold. For tax year 2024, single status filers can claim up to $14,600 as a standard deduction. Therefore, if one can maintain and produce supporting documentation that the tax year’s income is below the standard deduction threshold, the taxpayer may opt to not file a U.S. Income Tax Return. However, it’s good practice to still file a tax return  to show the U.S. Internal Revenue Service that your income is below the standard deduction and should generally yield a $0 tax liability. However, if a taxpayer’s worldwide income exceeds the standard deduction, one should prepare and file an income tax return. Failure to file can lead to penalties and interest and this results in a delinquent status, whether for paying or filing.

Furthermore, there are various considerations for having consistent annual tax returns. Specifically, two U.S. immigration-related examples come to mind:

1) Petitioning family members;  

 2) Renouncing  U.S. Citizenship.

For both scenarios, the U.S. government requires evidence of U.S. tax filing .

While there are several avenues to remedy a delinquent status, let’s focus on the following two examples:

  1. File the missing years as soon as possible, and pay any taxes owed (preparers can compute estimated penalties and interest or taxpayers can wait for IRS assessments and notices); or
  2. Go through an IRS Amnesty Program (eligible U.S. taxpayers may qualify for the Streamlined Foreign Offshore Procedures).

The Streamlined Foreign Offshore Procedures  (“SFOP”) stipulate specific eligibility and filing requirements. Some of these are that the failure to file and pay was non-willful and that the taxpayer must meet the non-residency requirement of being physically present outside the United States for at least 330 full days for the last three years and filing of Financial Crimes Enforcement Network Form 114, also referred to as the Report of Foreign Financial Accounts, among others.

Our team can assess and help determine if the SFOP would be a suitable approach for delinquent tax filers.

Frequently Asked Questions

Do U.S. citizens living and working in Vietnam need to file U.S. taxes?

Yes. The United States taxes based on citizenship, not residence. All U.S. citizens, wherever they live in the world, must report their worldwide income to the IRS each year if their income exceeds the applicable filing threshold. For a single filer under 65, this threshold is $14,600 for tax year 2025. Even if income falls below the threshold, filing a return is still recommended to document compliance with the IRS.

What is the SFOP and who qualifies?

The Streamlined Foreign Offshore Procedures (SFOP) is an IRS amnesty program for U.S. citizens abroad who have been non-compliant with their tax obligations in a non-willful manner. Key requirements include living outside the U.S. for at least 330 days in at least 1 of the 3 most recent tax years, certifying that non-compliance was not intentional, filing 3 years of missing returns, filing 6 years of missing FBAR reports and paying all taxes owed plus interest. The major benefit is that qualified participants pay no penalties. Arancel Consulting can assess whether you qualify.

What is FBAR and do I need to file it?

FBAR (FinCEN Form 114) is the Foreign Bank Account Report that U.S. citizens must file if the total balance of their foreign financial accounts exceeds $10,000 at any point during the year. This includes bank accounts in Vietnam, the Philippines or any other country. FBAR is filed separately from the tax return through the BSA E-Filing System. Penalties for non-willful failure to file can reach $10,000 per year.

I have not filed U.S. taxes for several years. What should I do now?

Two main options are available: (1) file all missing returns immediately for every outstanding year and pay taxes owed along with any penalties, or (2) participate in the SFOP program if you qualify, which may allow you to resolve the situation without penalties. The key is to act as soon as possible since penalties and interest accumulate over time. Arancel Consulting, in partnership with Enterline and Partners, can assess your specific situation and recommend the most appropriate course of action.

How does delinquent U.S. tax filing affect a family sponsorship petition?

When filing Form I-864 (Affidavit of Support) to sponsor a family member for a Green Card, USCIS requires the most recent 3 years of IRS tax returns. If returns are missing or unfiled for any of those years, the petition will be rejected or returned with a request for explanation, causing significant delays. Resolving any tax delinquency before or at the same time as filing the sponsorship petition is strongly recommended.

ABOUT ARANCEL CONSULTING

Arancel Consulting is a boutique U.S. Tax and Consultancy firm based in Manila, Philippines. The firm specializes in U.S. Expatriate Tax Compliance, U.S. Tax Consultancy, and U.S. Business Management Services. The firm partners with Enterline Partners for U.S. immigration referrals and consular services.

ENTERLINE & PARTNERS CONSULTING   

Ho Chi Minh City, Vietnam Office   

146C7 Nguyen Van Huong St, Thao Dien Ward,   
District 2, Thu Duc City   
Ho Chi Minh City, Vietnam   

Tel: +84 933 301 488   
Email: info@enterlinepartners.com   
Facebook: Enterline & Partners – Dịch vụ Thị thực và Định cư Hoa Kỳ   
YouTube: @EnterlineAndPartnersConsulting   
Website: http://enterlinepartners.com   

Manila, Philippines Office   

LKG Tower 37th Floor  
6801 Ayala Avenue   
Makati City, Philippines 1226   

Tel: +63 917 543 7926   
Email: info@enterlinepartners.com   
Facebook: Enterline and Partners Philippines   
Website: https://enterlinepartners.com/language/en/welcome/   

Copyright 2025. This article is for information purposes only and does not constitute legal advice. This article may be changed with or without notice. The opinions expressed in this article are those of Enterline & Partners only. 

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