A U.S. federal return appears to have been required for 2024 and 2025, and those years have passed their filing deadline. An FBAR also appears to be required for 2024, 2025 and 2026, which is a separate filing to FinCEN rather than part of the return. Your answers are consistent with the Streamlined Foreign Offshore procedures, which is a possibility to have reviewed rather than a conclusion: eligibility depends on a certification only you can make. 2 open questions below would firm this up, and they are listed in the order that matters.
Rules 2026.09.1 · sources src-c7d0b014
What would change this
- · The total value of your non-U.S. financial assets at year end, and at their highest point during the year, for 2020, 2021, 2022 and 2023. Form 8938 has two separate tests and they use different figures.
- · Your gross income for 2020.
Year by year
| Year | Return | Timeliness | FBAR | Form 8938 | Due |
|---|---|---|---|---|---|
| 2026 | Return likely required | Current | Required | Not indicated | 2027-06-15 |
| 2025 | Return required | Late | Required | Not indicated | 2026-06-15 |
| 2024 | Return required | Late | Required | Not indicated | 2025-06-16 |
| 2023 | Return required | Current | Not indicated | Not enough information | 2024-06-17 |
| 2022 | Return required | Current | Not indicated | Not enough information | 2023-06-15 |
| 2021 | Return required | Current | Not indicated | Not enough information | 2022-06-15 |
| 2020 | Not enough information | Current | Not indicated | Not enough information | 2021-06-15 |
Why
The 2026 return is not late
The 2026 return is not due until June 15, 2027, which reflects the automatic two-month extension for taxpayers whose tax home and abode are both outside the United States. That extension postpones filing, not paying: interest on any balance runs from the April date. A year that has not reached its deadline is an upcoming obligation, never a delinquent one.
Rules: Current year is not late; Automatic two-month extension for taxpayers abroad
2026 gross income reaches the filing threshold
Gross income of between $61,430.07 and $69,054.37 meets the 2026 threshold of $16,100 for a single filer. 2026 standard deduction of $16,100 for a single filer. Because the IRS has not published a 2026 exchange rate yet, this comparison was run at both the highest and the lowest rate on record for your currency, and it holds at both.
Rules: Form 1040 gross-income filing threshold; Income in a foreign currency for a year with no published rate
Being able to exclude the income does not remove the filing requirement
The gross-income test is applied before the foreign earned income exclusion. Even where the exclusion would remove all of the U.S. tax, it is claimed on a return, so the return still has to be filed to claim it.
Rules: Excludable income still counts toward the filing threshold
2025 gross income reaches the filing threshold
Gross income of $65,936.79 meets the 2025 threshold of $15,750 for a single filer. 2025 standard deduction of $15,750 for a single filer.
Rules: Form 1040 gross-income filing threshold
Being able to exclude the income does not remove the filing requirement
The gross-income test is applied before the foreign earned income exclusion. Even where the exclusion would remove all of the U.S. tax, it is claimed on a return, so the return still has to be filed to claim it.
Rules: Excludable income still counts toward the filing threshold
The 2025 return appears to be late
The 2025 threshold was met, the due date of June 15, 2026 has passed, and no return was filed. Both halves matter: a year with no filing requirement is never delinquent, however many unfiled years surround it.
Rules: Return was required and the due date has passed
2024 gross income reaches the filing threshold
Gross income of $63,225.11 meets the 2024 threshold of $14,600 for a single filer. 2024 standard deduction of $14,600 for a single filer.
Rules: Form 1040 gross-income filing threshold
Being able to exclude the income does not remove the filing requirement
The gross-income test is applied before the foreign earned income exclusion. Even where the exclusion would remove all of the U.S. tax, it is claimed on a return, so the return still has to be filed to claim it.
Rules: Excludable income still counts toward the filing threshold
The 2024 return appears to be late
The 2024 threshold was met, the due date of June 16, 2025 has passed, and no return was filed. Both halves matter: a year with no filing requirement is never delinquent, however many unfiled years surround it.
Rules: Return was required and the due date has passed
Catch-up route
Possible Streamlined Foreign Offshore review
Relief worth comparing
Foreign earned income exclusion (Form 2555) Worth comparing
Earned income from working abroad may be excludable if you meet the bona fide residence or the physical presence test. It is worth comparing, with two caveats: it applies only to earned income, and it does not reduce self-employment tax.
Foreign tax credit (Form 1116) Worth comparing
Income tax paid abroad may be creditable against the U.S. tax on the same income. Not every foreign levy qualifies, and the credit is computed per category of income, so it is worth comparing against the exclusion rather than assuming one is better.
Which route leaves you better off Not indicated
Choosing between the exclusion and the credit means computing the return both ways. That is preparation work, not assessment work, and this diagnostic deliberately stops before it rather than guessing. Nothing here should be read as a promise that no U.S. tax will be due.
What to do next
- 1
Plan to file your 2020 return by 2021-06-15.
This is the nearest deadline that applies to you. Filing on time is materially cheaper and simpler than catching up later.
- 2
Decide how to bring 2025, 2024 up to date.
Your answers point toward the Streamlined Foreign Offshore procedures, which need a professional to confirm before you commit to them.
- 3
Gather the highest balance for each non-U.S. account for 2026, 2025, 2024.
The FBAR asks for a maximum value per account per year, and reconstructing it later is the slowest part of any catch-up.
- 4
Answer the open questions listed in this report.
2 questions would change or firm up a conclusion above.
Recommended next step
Streamlined Investor
Your answers point toward a Streamlined submission and you hold non-U.S. funds, which is the work the Investor tier covers. The final scope is confirmed before anything is billed.
- List price
- $2,200
- Diagnostic credit
- −$100
- You pay
- $2,100
What this rested on
- · Every conclusion rests on the answers given. Nothing was verified against a document, a bank record or an IRS transcript.
Official sources
- 26 C.F.R. §1.6081-5 · checked 2026-09-08
- IRS · International Taxpayers · checked 2026-09-08
- IRS Publication 54 · checked 2026-09-08
- IRS Publication 501 · checked 2026-09-08
- 26 U.S.C. §6012 · checked 2026-09-08
- IRS Interactive Tax Assistant · checked 2026-09-08
- IRS Form 2555 instructions · checked 2026-09-08
- FinCEN Form 114 · checked 2026-09-08
- 31 C.F.R. §1010.350 · checked 2026-09-08
- IRS comparison table · checked 2026-09-08
- IRS Form 8938 instructions · checked 2026-09-08
- 26 U.S.C. §6038D · checked 2026-09-08
- IRS Form 8621 instructions · checked 2026-09-08
- IRS · Streamlined Foreign Offshore Procedures · checked 2026-09-08
- IRS · Streamlined Filing Compliance Procedures · checked 2026-09-08
- IRS Form 14653 · checked 2026-09-08
- IRS Form 1116 instructions · checked 2026-09-08