For most Americans who live outside the United States, the tax year never really ends in April. It ends in the autumn. If you used the extensions available to you for your 2025 federal return, the last ordinary date to file it is Thursday, 15 October 2026. The same day is the last date of the automatic extension for the FBAR, the separate report of foreign bank and financial accounts.
Three days before that date is a good moment to check what is actually due, what the extension has and has not done for you, and what happens if you miss it. The rules below come straight from the IRS's own guide for citizens abroad, Publication 54, and from the IRS and FinCEN pages on the FBAR.
How an American abroad arrives at 15 October
The regular due date for a calendar-year individual return is 15 April. Americans abroad get more time, in two steps.
Step one is automatic. If on the regular due date you live outside the United States and Puerto Rico and your main place of business or post of duty is also outside both, you get an automatic two-month extension to 15 June. You do not apply for it. You attach a statement to your return explaining which of the qualifying situations applied to you.
Step two has to be requested. If you could not file by 15 June, you could get an additional four months, to 15 October, by filing Form 4868 by the June date. Publication 54 is explicit that both the two-month and the six-month periods are counted from 15 April, which is why the end point is 15 October and not mid-December. The IRS's general extension page lists the ways to request it: paying online and ticking the extension box, using Free File, or sending Form 4868 by mail.
If you requested that extension in June, your 2025 return is due this Thursday. If you did not, the June deadline has already passed and the question is a different one, covered further below.
The one thing the extension never did
The extension to October is time to file. It is not time to pay. The IRS says so on its extension page: the extension is only for filing the return, and any tax owed was due by the April filing date. The automatic two-month extension differs in one respect, according to Publication 54: it extends the time to pay as well, so the penalty for paying late is assessed from 15 June rather than 15 April. Interest is another matter. On any tax not paid by 15 April, interest runs from that date in every case, with or without an extension.
For many Americans abroad the balance due is zero. The foreign tax credit and the foreign earned income exclusion often eliminate the US tax on salary earned in a higher-tax country. But that is not universal. People in low-tax or no-tax countries, people with US-source investment income, and people caught by the net investment income tax often do owe something. The Brief looked at the last of these in its piece on the Bruyea ruling and the NIIT for Americans abroad. If you owe, interest has been running since April. Filing on 15 October stops the filing penalty from starting; it does not undo the interest.
A last extension to 15 December, by letter
Publication 54 describes one more step that is easy to overlook. Taxpayers who are out of the country can request a discretionary additional two months, to 15 December. There is no form. You send the IRS a letter explaining why you need the extra time, and you must send it by the extended due date of 15 October. The IRS only writes back if it denies the request.
Two limits matter. The extension is discretionary, so it is not a right. And it is not available to anyone who already holds an approved extension on Form 2350.
Form 2350: the extension for people who have not yet qualified
Form 2350 is a separate tool for a specific problem. To claim the foreign earned income exclusion or the housing exclusion, you must pass either the bona fide residence test or the physical presence test (330 full days abroad in a 12-month period). In the first year abroad you often cannot pass either test by the normal deadline.
Publication 54 lets you apply on Form 2350 for an extension to a date after you expect to qualify, generally 30 days beyond it. The Form 2555 instructions set out the alternative: file on time without the exclusion and later amend with Form 1040-X once you qualify. Either way, interest is charged on tax not paid by 15 April. If you moved abroad during 2025 and have a Form 2350 extension, your date is the one on that approval, not 15 October.
The numbers on the 2025 return
A few figures are worth having in front of you before you file.
- Foreign earned income exclusion for 2025: $130,000 per qualifying person, according to the 2025 Form 2555 instructions. A married couple who both work abroad and both qualify can each claim it.
- Housing expense limit for 2025: in most locations $39,000 (30% of $130,000) for a full-year qualifying period, higher in the high-cost locations listed in IRS Notice 2025-16.
- Looking ahead: Revenue Procedure 2025-32 sets the exclusion for 2026 at $132,900. That figure belongs on next year's return, not this one.
The exclusion is an election. It has to be claimed on Form 2555, and it covers earned income only. Pensions, dividends, interest, rental income and capital gains are not excluded by it.
The FBAR is a separate filing, with the same date
The FBAR (FinCEN Form 114) is not part of your tax return. It goes to the Financial Crimes Enforcement Network, not to the IRS, and it is filed electronically through the BSA E-Filing System. FinCEN's FBAR page notes that individuals can file without registering for an account.
The test is simple and catches more people than they expect. A US person must file if they had a financial interest in, or signature or other authority over, foreign financial accounts whose aggregate value exceeded $10,000 at any time during the calendar year. Aggregate means all accounts together. Three accounts with $4,000 each, if their combined balance passed $10,000 on a single day, are enough. Whether the account produced any income does not matter.
On timing, the IRS FBAR page says the report is due 15 April, with an automatic extension to 15 October. You do not need to request it. The 2025 FBAR is therefore due on the same Thursday as an extended 2025 return. Unlike the tax return, the FBAR has no discretionary extension to December. The IRS page mentions further extensions in two cases only: people covered by relief notices, for example after natural disasters, and certain employees or officers who have signature authority over, but no financial interest in, an employer's foreign accounts.
Form 8938: same accounts, different form, higher thresholds
Form 8938 overlaps with the FBAR but is a different obligation. It is filed with the tax return, so its deadline is the return's deadline. The Form 8938 instructions set much higher thresholds for people who meet the presence abroad test, meaning a bona fide resident of a foreign country for a full tax year or someone present abroad at least 330 full days in a 12-month period ending in the tax year:
- Unmarried, or married filing separately: more than $200,000 on the last day of the year, or more than $300,000 at any time during the year.
- Married filing jointly: more than $400,000 on the last day of the year, or more than $600,000 at any time during the year.
Many people abroad must file the FBAR but not Form 8938. Fewer must file Form 8938 but not the FBAR. Checking both every year is the only safe habit.
What happens if you miss 15 October
The IRS's failure-to-file penalty is 5% of the unpaid tax for each month or part of a month the return is late, up to a maximum of 25%. For a return more than 60 days late with an original due date after 31 December 2025, the minimum penalty is $525 or 100% of the unpaid tax, whichever is less. The penalty does not apply if you can show reasonable cause.
The arithmetic contains an important point. The penalty is a percentage of tax due. If your foreign tax credits or exclusion reduce your US tax to zero, a late return generally produces no failure-to-file penalty under this calculation. That is not a reason to file late. Several of the elections that bring the tax down, the foreign earned income exclusion among them, depend on rules about when and how they are claimed, and information returns carry their own penalties that do not depend on tax owed.
If you are years behind rather than days
Some readers will not be facing a missed October deadline but several missed years. The IRS's Streamlined Foreign Offshore Procedures exist for exactly that situation, on conditions:
- The failures must have been non-willful, meaning negligence, inadvertence, mistake or a good-faith misunderstanding of the law.
- US citizens and green card holders must meet a non-residency requirement: in at least one of the most recent three years for which the due date has passed, no US abode and at least 330 full days outside the United States.
- You submit the outstanding returns and FBARs with a signed certification of non-willful conduct: tax returns for the most recent three years for which the due date has passed, and FBARs for the most recent six years.
Missing one October date does not, by itself, put anyone in streamlined territory. But for people who discover the whole system late, often after a bank asks for a US tax number, it is the route the IRS itself publishes.
Why it matters beyond the money
Two consequences reach further than penalties.
The first is your passport. Publication 54 reminds readers that the IRS must notify the State Department of taxpayers certified as owing a seriously delinquent tax debt, and that the State Department is generally prohibited from issuing or renewing a passport for them, and may revoke one.
The second is banking. Foreign banks report US account holders under FATCA. Your returns, your FBARs and what the banks report are increasingly compared. The Brief's piece on proving tax residency makes the broader point: a consistent paper trail is what keeps accounts open and questions short.
A checklist for the next three days
- Confirm your date. Form 4868 filed by 15 June means 15 October. An approved Form 2350 means the date on the approval.
- File the FBAR separately, through BSA E-Filing, if your foreign accounts together passed $10,000 at any point in 2025.
- Check Form 8938 against the abroad thresholds and attach it to the return if required.
- Attach the abroad statement if you relied on the automatic June extension.
- Pay what you owe now. Interest has run since April and keeps running.
- If you genuinely need more time and are out of the country, send the IRS a letter by 15 October asking for the discretionary extension to 15 December, unless you hold a Form 2350 extension.
None of this is new law. It is the ordinary calendar of a citizen-based tax system, which the Brief explained in why America still taxes you abroad. The United States country page covers the domestic side for people who move there. For Americans who live elsewhere, 15 October is simply the day the previous year finally closes.
Work with Sebastian
If you are an American living abroad and your US filings, foreign accounts and residence no longer tell one consistent story, that is the kind of cross-border setup Sebastian works on with internationally mobile clients. Book a consultation.
