TP will be filing form 14653 (Streamlined Foreign Offshore Procedures), it requires 3 years past (2018, 2017 and 2016) returns and 6 years FinCen114 (2018, 2017, 2016, 2015, 2014 and 2013).

However, the last time TP filed f1040 and FinCen 114 was tax year 2013, My first question is for f14653, can TP just file 5 years (2018, 2017, 2016, 2015 and 2014) FinCen114 instead of 6 years?

My second question is PTO just informed me that TP cannot efile FinCen 114 for tax year 2016 and earlier. Is there any other way to do efiling for those years?

Thanks for your time and comment.