October 15: final deadline for your 2025 US tax return and FBAR
On October 15, 2026, the extended deadline for your 2025 income tax return and the automatic FBAR extension both run out. Here is what a missed deadline costs, and which path is open to you if you have never filed at all.
Lena was born in Boston on a snowy January day, while her father spent two years doing research at a hospital there. When she was three, the family moved back to Hamburg. She went to school there, studied there, and today works as an architect in the city's Altona district. She speaks English with a northern German accent. To her, America is a birthplace in her passport, nothing more.
Until the day her bank sends her a questionnaire asking her to tick a box: is she a US person for American tax purposes?
Lena is thirty-two. She has never filed an American tax return. And this week a deadline expires that, until recently, she did not even know existed.
Two deadlines on one day
On Thursday, October 15, 2026, the extended deadline for the 2025 US income tax return expires. If you requested an extension in April with Form 4868 or through a payment marked accordingly, you now have to file. A further extension is only available to taxpayers living abroad.
The automatically extended deadline for the FBAR, the report of foreign bank accounts to the Treasury Department, ends on the same day. According to the IRS, the regular deadline is April 15, and anyone who misses it automatically gets until October 15, with no need to request anything.
Americans living abroad also received an automatic two-month extension to mid-June. If they requested the further extension, their deadline also ends on October 15, unless they ask the IRS by letter before then for an additional two-month extension to December 15, which is granted at the IRS's discretion.
Who is affected
More people in Europe than you might think.
American citizens living in Europe. The United States taxes its citizens worldwide, wherever they live. That applies to people like Lena, who just happened to be born in the US, just as much as to children of European parents who were born during a stay abroad. How far this obligation reaches is something we covered in June in Six justices confirmed today that your Texas-born child is an American.
Green card holders, even if they moved back to Europe long ago, as long as the green card has not been properly surrendered.
People without a US passport who have US income. If you rent out a holiday home in Florida, are a partner in an American partnership or worked in the US for a while, you file a nonresident return, Form 1040-NR. We explained what applied in April in Tomorrow is Tax Day, and the IRS doesn't care whether you're in Austin or abroad.
Five percent per month or part of a month
The April extension was an extension to file, not to pay. If you owe tax, it was due by April 15. Interest runs on everything unpaid since then: according to the IRS, seven percent a year for the fourth quarter of 2026, compounded daily.
If you file after October 15, you also pay the failure-to-file penalty. According to the IRS, it is five percent of the unpaid tax for each month or part of a month, up to 25 percent. If the return is more than 60 days late, a minimum penalty applies. For returns due after December 31, 2025, it is $525 or 100 percent of the unpaid tax, whichever is less.
The FBAR has its own penalties, which can become ruinous for willful violations. Even for negligent failures, the law provides penalties per report. How it all fits together is explained in our April article, Two forms nobody knows, and penalties everybody feels.
An example, worked through
Thomas from Innsbruck owns an apartment in Naples, Florida, which he rents to vacationers. In April he requested an extension because the statement from his management company was missing. According to his return, he still owes $4,000 for 2025.
If he files and pays by Thursday, he pays the $4,000 plus interest since April 15 and the failure-to-pay penalty, which at half a percent per month is much lower than the failure-to-file penalty.
If he waits until January to file, three months or part-months after the deadline, the failure-to-file penalty is added. Five percent for each of the three months comes to as much as 15 percent, which on $4,000 means up to $600. The minimum penalty of $525, which applies when a return is more than 60 days late, doesn't matter in his case because the calculated amount is higher. With a smaller balance due, it would be the floor. On top of that, interest keeps running, month after month.
A few hundred dollars for a few weeks' delay. It's not the end of the world. But it's money Thomas could have saved with one appointment this week.
And Lena?
For Lena, October 15 is not the deadline that matters, and that is the real good news of this article. She hasn't missed one return, she has missed all of them. The IRS has a dedicated procedure for people in her situation, designed for exactly these cases.
The Streamlined Foreign Offshore Procedures are for taxpayers who live abroad and whose failure to comply was not willful. Under the IRS requirements, they file the returns for the last three years whose deadlines have passed and the FBARs for the last six years, pay any tax and interest due, and certify in writing that their failure was not willful.
According to the IRS, if you are eligible and meet all the requirements, you face no failure-to-file or failure-to-pay penalties, no accuracy-related penalties, no information return penalties and no FBAR penalties. For someone like Lena, who pays taxes in Hamburg that as a rule exceed the US tax, the procedure often ends without any payment to the IRS at all. There's no guarantee of that, but it is the typical outcome.
What you shouldn't do: wait until the IRS contacts you. The procedure is only open as long as the IRS has not started an examination. If you only react once a letter arrives, that door may already be closed. More on our Streamlined Filing page.
Why the bank's questionnaire is no coincidence
Lena's bank didn't ask out of curiosity. For years, international agreements have required European banks to identify accounts held by US persons and report them to the tax authorities. Because of her birthplace, the bank considers Lena a US person, regardless of whether she feels like one.
Many people in Lena's situation learn about their obligation this way for the first time. Some run into trouble opening an account, an investment account or getting a mortgage. A clean tax record in America doesn't always solve these problems right away, but it is what makes solving them possible in the first place.
And the states?
The October 15 deadline is about federal tax. Many states have their own income taxes, with their own returns and their own extension rules. If your income comes from property in Florida, you're in luck: Florida has no personal income tax, and neither does Texas. But if you rent out an apartment in New York or California, you have to file there too, and those deadlines don't always line up with the federal one.
So if you only think about the IRS, you may have forgotten half the picture.
Four situations, four next steps
If you extended in April: File by Thursday, even if a document is still missing. A return can be amended later. A missed deadline can't be undone.
If you have to file an FBAR: Check whether the combined balance of your accounts outside the US exceeded $10,000 at any point in 2025. If it did, the report is due, electronically, by Thursday.
If you have never filed a return: Don't panic, and don't try to catch up on six years by Thursday. Have someone check whether the Streamlined procedure is right for you, and prepare it carefully.
And if you have an LLC with no business in the US and someone told you about a $25,000 penalty: that concerns a different form and a different structure. You'll find the answers on our sister site zerotax.llc.
A question we received this week
Over the weekend, someone wrote to us: what happens if I don't file by October 15? The answer is neither reassuring nor dramatic, but exactly what American tax law usually is: it depends on what you owe, which form we're talking about and whether you acted willfully.
For an ordinary income tax return with a small balance due, the consequences are manageable. For someone who owes tax and does nothing, they grow every month. And for someone who didn't know for years, there is a way back that is friendlier than its reputation.
That may be the most important message for people like Lena. The IRS is not an agency that rewards ignorance. But it does distinguish between someone who hides and someone who comes forward on their own.
How we help
Our team in Austin has been preparing American tax returns for people in Europe since 2008, for residents and nonresidents alike. If your 2025 return is still outstanding, we'll handle your US tax return, including filing with the IRS. If several years are missing, we guide you through the Streamlined procedure from review to submission. Everything else we do for individuals is under Tax Services for Individuals, our US Taxes guide gives you the overview of American tax law, and all services with fees are under Services & Fees.
On Monday evening, Lena gathered her paperwork: her payroll tax statements for the last three years, her bank statements, a copy of the American passport she hasn't used since she was a child. It feels like opening a door with something terrible waiting behind it. What she'll actually find is a form, a process and, if all goes well, a tax bill of zero dollars.
Sometimes the scariest thing about America is simply not knowing where to start.
Consultation & implementation
If you'd like to find out what this means for your own situation, the best step is to book a consultation.