A U.S. federal return looks likely to be required for 2020, and it is not late: it falls due on June 15, 2021. 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. 6 open questions below would firm this up, and they are listed in the order that matters.
Example case map
Built from your answersYou
U.S. citizen living in Germany (composite example)
What happened
Filing stopped after two years; a German brokerage account was overlooked
Potential filings
Form 1040 · Form 8621 · Schedule B, Part III · FBAR · Form 8938
Read and next step
Review required · Not enough information to choose a route · Review the report
Rules 2026.10.11 · sources src-d0e481da:deadline-sources@f7548d3d3badc10a2b6b6f06e7fe64e4949443ecfdfca57b0d59167a3dbe54f1
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.
- · Confirm IRS-2025-53 eligibility for this subject and act; earlier eligibility does not establish later eligibility.
- · Confirm IRS-2024-72 eligibility for this subject and act; earlier eligibility does not establish later eligibility.
- · Confirm IRS-2023-71 eligibility for this subject and act; earlier eligibility does not establish later eligibility.
- · Confirm obligation-specific deadlines before selecting a catch-up procedure. Any effect of postponements on SFOP filing periods requires separate professional interpretation.
Year by year
Tax year 2026
- Return
- Return likely required
- Timing
- Upcoming
- FBAR
- Required
- Form 8938
- Not indicated
- Return deadline
- 2027-06-15
Tax year 2025
- Return
- Return required
- Timing
- Unknown
- FBAR
- Required
- Form 8938
- Not indicated
- Return deadline
- 2026-06-15
Tax year 2024
- Return
- Return required
- Timing
- Unknown
- FBAR
- Required
- Form 8938
- Not indicated
- Return deadline
- 2025-06-16
Tax year 2023
- Return
- Return required
- Timing
- Current
- FBAR
- Not indicated
- Form 8938
- Not enough information
- Return deadline
- 2024-06-17
Tax year 2022
- Return
- Return required
- Timing
- Current
- FBAR
- Not indicated
- Form 8938
- Not enough information
- Return deadline
- 2023-06-15
Tax year 2021
- Return
- Return required
- Timing
- Current
- FBAR
- Not indicated
- Form 8938
- Not enough information
- Return deadline
- 2022-06-15
Tax year 2020
- Return
- Not enough information
- Timing
- Current
- FBAR
- Not indicated
- Form 8938
- Not enough information
- Return deadline
- 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 filing extension does not itself postpone payment; evaluate any separate payment postponement before assessing interest. 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
An FBAR is indicated for 2025
The combined high value of your non-U.S. financial accounts, $46,275.39, exceeds the $10,000 threshold. The FBAR is filed with FinCEN rather than with the IRS, and the threshold is on the combined total of every account, not on any single one.
Rules: FBAR aggregate account threshold
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
An FBAR is indicated for 2024
The combined high value of your non-U.S. financial accounts, $44,372.29, exceeds the $10,000 threshold. The FBAR is filed with FinCEN rather than with the IRS, and the threshold is on the combined total of every account, not on any single one.
Rules: FBAR aggregate account threshold
Catch-up route
Not enough information to choose a route
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
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.
- 3
Answer the open questions listed in this report.
6 questions would change or firm up a conclusion above.
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 Form 1116 instructions · checked 2026-09-08