US Tax Preparation for American Expats: Which Years Count
US tax preparation for American expats: see which three tax years and six FBAR years a streamlined pack filed now covers — and book a confidential review.
Three returns, six years, misaligned
A streamlined submission assembled in late July 2026 normally carries three federal returns — tax years 2023, 2024 and 2025 — against six FBAR years, 2019 through 2024. The two windows do not overlap, because each is measured from its own passed due date. A valid extension to 15 October 2026 changes the return years entirely.
That single sentence causes more rework in US tax preparation for american expats than any other point of technique. The IRS never publishes a fixed list of years for the Streamlined Foreign Offshore Procedures. It publishes a formula, and the formula moves. At Jungle Tax we date-stamp every streamlined pack at the moment of assembly and re-test the year set before it leaves the office, because a pack that was correct in September can be defective in November.
What does the IRS actually require, and why is it a moving target?
The governing language on the IRS U.S. taxpayers residing outside the United States page is deliberately relative rather than absolute. For income tax returns, you file for the most recent three years for which the U.S. tax return due date — or properly applied for extended due date — has passed. For foreign account reporting, you file delinquent FBARs for each of the most recent six years for which the FBAR due date has passed.
Two consequences follow, and sophisticated filers should hold both in mind:
- The window is anchored to due dates, not to calendar years. Tax year 2025 does not enter the three-year set on 1 January 2026. It enters when its due date passes.
- Your own filing behaviour moves the anchor. Because the test reads "or properly applied for extended due date," a taxpayer who filed a valid extension request has a later anchor than one who did not — and therefore a different, older set of three years.
This is not a technicality. Form 14653 is signed under penalty of perjury and certifies, among other things, that all required FBARs have now been filed. A year set built on the wrong anchor date undermines the certification itself, which is the one document in the pack you cannot afford to get wrong.
Which years does a streamlined pack prepared now actually cover?
Work through the anchors as they stand in the second half of 2026.
The income tax returns: 2023, 2024 and 2025 in the default case
Americans whose tax home and abode are outside the United States receive an automatic two-month extension to 15 June. For tax year 2025 that date was 15 June 2026. It has passed. Tax year 2025 is therefore inside the window, and the three most recent years for which a due date has passed are 2023, 2024 and 2025. Tax year 2022 has dropped out.
If you have never filed for those years, each is prepared as a complete original Form 1040 with all required international information returns attached. If you filed thin or incorrect returns — a common pattern where a UK-resident client reported employment income but omitted an ISA, a self-invested personal pension or a UK-resident company interest — those years go in on Form 1040-X instead. Mixed packs are entirely normal: two originals and one amendment, for example.
The FBARs: 2019 through 2024
FinCEN Form 114 for calendar 2025 was due on 15 April 2026, and as the IRS FBAR guidance confirms, every filer receives an automatic extension to 15 October without requesting one. That extended date has not yet passed. The most recent FBAR year whose due date has genuinely passed is therefore calendar 2024, and the six-year set runs 2019, 2020, 2021, 2022, 2023 and 2024.
The reporting trigger is an aggregate — more than $10,000 across all foreign financial accounts at any moment in the calendar year, not $10,000 per account. Clients who dismiss the requirement because "no single account was ever large" are frequently wrong once a current account, a savings account, two legacy stakeholder pensions and a stockbroker account are added together on the peak day. Our FBAR penalty calculator is a useful way to see what the downside looks like if those years are left unfiled.
Why do the three-year and six-year windows not line up?
Because they are two separate statutes with two separate calendars, administered by two separate systems. Income tax returns run on Title 26 and go to the IRS in Austin on paper. FBARs run on Title 31, the Bank Secrecy Act, and are e-filed through FinCEN's BSA system. Nothing in either regime obliges the windows to coincide, and in practice they almost never do.
Laid against each other, a July 2026 pack looks like this:
| Year | Federal return (Form 1040 / 1040-X) | FBAR (FinCEN 114) | Status in a July 2026 pack |
|---|---|---|---|
| 2019 | Outside the three-year window | Required | FBAR only |
| 2020 | Outside the three-year window | Required | FBAR only |
| 2021 | Outside the three-year window | Required | FBAR only |
| 2022 | Outside the three-year window | Required | FBAR only |
| 2023 | Required | Required | Both |
| 2024 | Required | Required | Both |
| 2025 | Required | Not yet due (extended to 15 October 2026) | Return only |
Four years therefore sit in the pack as FBAR-only years, and one sits as a return-only year. That asymmetry has three practical consequences that generalist guides skate over.
- Records must be gathered for six years, not three. Peak balances and account details are needed for 2019 and 2020 even though no return is prepared for them. Under FBAR record-keeping expectations, statements should be retained for a period longer than the disclosure itself.
- An orphan FBAR year can still surface a tax problem. If 2020 shows a large UK pension lump sum or an unreported disposal, the year is outside the streamlined three-year return set — but it is not outside the IRS's assessment powers, and it is squarely inside HMRC's offshore assessment window. It needs a decision, not silence.
- Form 8938 tracks the returns, not the FBARs. The FATCA statement is filed with a Form 1040, so it exists only for the three return years. The 2019 to 2022 specified foreign financial assets are covered by the FBARs alone in this pack.
How does a valid extension to 15 October change the contents?
Materially, and in a direction most people find counter-intuitive. If a Form 4868 extension was properly filed for tax year 2025, the extended due date is 15 October 2026 and has not passed. Tax year 2025 is therefore not one of the years for which a due date has passed, and the three-year set rolls back to 2022, 2023 and 2024.
| Scenario as at late July 2026 | Return years | FBAR years | Practical read |
|---|---|---|---|
| No extension filed for 2025 | 2023, 2024, 2025 | 2019–2024 | Default position for most non-filers |
| Valid Form 4868 extension to 15 October 2026 | 2022, 2023, 2024 | 2019–2024 | Return and FBAR years align more closely |
| Pack filed after 15 October 2026 | 2023, 2024, 2025 | 2020–2025 | Both windows have rolled forward |
Notice the planning point buried in the middle row. Where a client is on extension, the streamlined pack covers 2022 to 2024 and tax year 2025 is filed separately as a normal, timely return by 15 October. That is often the cleaner outcome: the current year goes in through the front door as an ordinary compliant filing rather than as part of a delinquency package, and the six FBAR years bracket the three return years neatly.
Two cautions. First, an extension is only relevant if it was properly applied for — a genuine, timely Form 4868, not a retrospective assertion. A taxpayer who has never filed anything cannot claim an extended due date after the fact. Second, taxpayers abroad may in some circumstances obtain a further discretionary extension beyond October; where that has been requested, the anchor date shifts again and the year set must be re-tested rather than assumed.
What happens if a year drops out before the submission is filed?
This is the failure mode we see most often in packs prepared by generalist firms, and it is entirely avoidable. The year set is tested against the date the submission is actually filed and received — not the date you started gathering documents, and not the date the returns were drafted.
A concrete example. A pack is drafted in early September 2026 with returns for 2023 to 2025 and FBARs for 2019 to 2024. Signatures slip; the envelope is posted on 26 October 2026. In the interval, 15 October passed. Calendar 2025's FBAR due date has now passed, so the required six-year set is 2020 to 2025 — and the pack is missing the 2025 FBAR while carrying a 2019 FBAR that is no longer required. The Form 14653 certification that all required FBARs have been filed is now inaccurate on its face.
Our house rules on this are simple and worth adopting:
- Over-include rather than under-include. Filing a seventh FBAR year is harmless; omitting a required one is a defect in the certification. Where a submission is being assembled near a rollover date, we prepare both the outgoing and incoming years.
- Re-test the year set on the day of filing. A one-line check against the four dates that matter — 15 April, 15 June, 15 October and any discretionary extension date — takes minutes.
- Do not part-file. FBARs are e-filed and returns are posted, so they never arrive simultaneously; but they should be released within days of each other, and the FBAR reason-for-late-filing must be tagged to the streamlined procedures rather than left blank or given a generic explanation.
- Never let a rollover become a reason to delay. Waiting for a tidier year set is how a two-year delay becomes a five-year delay, and delay is one of the few facts that genuinely damages a non-willfulness narrative.
The 2026 to 2027 rollover calendar
- 15 October 2026 — extended due date for tax year 2025 passes; calendar 2025 FBAR due date passes. Return set becomes 2023–2025 for everyone; FBAR set becomes 2020–2025.
- Mid-December 2026 — where a further discretionary extension for a taxpayer abroad has been granted, that anchor date is the operative one for that taxpayer.
- 15 April 2027 and 15 June 2027 — tax year 2026 due dates. Once 15 June 2027 passes, the return set becomes 2024–2026 for a filer without an extension.
- 15 October 2027 — calendar 2026 FBAR anchor passes; FBAR set becomes 2021–2026.
How does the UK side interact with the same period?
For our clients — overwhelmingly Americans resident in the United Kingdom, and dual citizens who have lived here for decades — the streamlined window is only half the exercise. HMRC runs on an entirely different clock, and the years that matter there are wider.
| Feature | United States (IRS / FinCEN) | United Kingdom (HMRC) |
|---|---|---|
| Tax year | Calendar year to 31 December | 6 April to 5 April |
| Filing deadline | 15 April; 15 June if abroad; 15 October on extension | 31 January after the tax year ends (online) |
| Catch-up route | Streamlined Foreign Offshore Procedures, Form 14653 | Worldwide Disclosure Facility via the Digital Disclosure Service |
| Years in scope | 3 returns / 6 FBARs, by passed due date | Driven by behaviour: broadly 4, 6, 12 or 20 years |
| Penalty on a clean non-willful case | Nil title 26 and title 31 penalties; tax and interest only | Penalty bands apply, mitigated by unprompted disclosure |
| Foreign account reporting | FinCEN 114 and Form 8938 | No standalone equivalent; income and gains reported on the return |
Three cross-border points deserve emphasis, because they are exactly where single-jurisdiction advisers come unstuck.
The straddle problem
UK tax years straddle US ones. A US return for calendar 2024 draws on parts of UK 2023/24 and 2024/25. Foreign tax credits claimed on Form 1116 for those years therefore have to be built from apportioned UK figures and, where relevant, from UK liabilities that were themselves only settled later. Recalculating credits across three US years assembled from four UK years is the single most labour-intensive part of a well-built pack, and it is where an unreliable pack is usually exposed. Our UK tax services and US tax services teams reconcile both sides from the same underlying data set precisely to avoid that.
HMRC's window is wider than the IRS window
Where a UK return was also wrong — an unreported US brokerage account, a US LLC, foreign dividends omitted because they were taxed at source — HMRC's assessment period for offshore matters extends considerably beyond four years, and the Worldwide Disclosure Facility requires you to calculate what is owed year by year according to your own characterisation of the behaviour. Notify first, then you have 90 days to deliver the disclosure. A streamlined submission covering three US years sitting alongside a UK position covering twelve is a normal, not an exotic, shape for these engagements.
Consistency between the two narratives
Form 14653 asks for a factual explanation of why the failures happened. That narrative and any WDF disclosure narrative must be capable of standing side by side. Both are read by revenue authorities that exchange information under the intergovernmental agreement, and an FBAR-only year such as 2020 or 2021 can appear in one story and not the other. Drafting the two accounts in isolation is how inconsistencies get created; drafting them together is the point of using a single cross-border team.
What else changes the contents of the pack?
- Missed information returns. Forms 5471, 8865, 3520 and 3520-A go in with the return year to which they relate. A UK personal service company or a family trust interest frequently expands the pack far beyond the 1040 itself.
- Non-residency test years. Eligibility for the foreign — rather than domestic — procedures depends on failing the substantial presence test and having no US abode in at least one of the three return years. Because the three return years move, so can eligibility. A client who was in the US for most of 2022 may qualify comfortably on a 2023–2025 set and awkwardly on a 2022–2024 set.
- Payment. Tax and interest for the three return years are due with the submission. Interest accrues to the payment date, so a figure calculated in July should be refreshed before filing.
- Ongoing years. Once the pack goes in, every subsequent year must be filed on time. Nothing damages a streamlined position faster than a fresh delinquency arising after the certification was signed.
Speak to us before you fix the year set
The year set is the first decision in a streamlined submission and the one that quietly determines whether everything downstream holds together. If you are weighing up a catch-up now, we will confirm your exact return and FBAR years against your own extension history, model the tax and interest, and tell you plainly whether the streamlined route or another path fits your facts. Our IRS streamlined filing specialists handle nothing else. To discuss your position in confidence and without obligation, contact our cross-border team.
