The tax year and filing deadlines in the United States, Canada and India do not line up, and that mismatch is the source of many cross-border mistakes. Individuals in the U.S. and Canada file on a calendar year, while India's financial year runs from April 1 to March 31. A single family can face an April 15 deadline in Illinois, an April 30 deadline in Ontario and a July 31 deadline in India for what feels like the same twelve months. This page compares the three systems for the 2025 filing season, notes what changes for 2026 and explains the practical consequences.
How do the three tax years work?
| Feature | United States | Canada | India |
|---|---|---|---|
| Individual tax year | Calendar year (January 1 to December 31) | Calendar year | Financial year April 1 to March 31 |
| Name used for income earned in 2025 | Tax year 2025 | 2025 tax year | Financial year 2025-26, assessment year 2026-27 under the 1961 Act |
| Corporations | May choose a fiscal year | A fiscal period chosen by the corporation | Generally April 1 to March 31 for Indian companies |
| Law governing the period | Internal Revenue Code | Income Tax Act (Canada) | Income-tax Act, 1961 up to March 31, 2026; Income-tax Act, 2025 from April 1, 2026 |
India's new Act replaces the "previous year" and "assessment year" pair with a single "tax year" for periods beginning April 1, 2026. The Press Information Bureau confirms the Act came into force on April 1, 2026, with new rules and forms notified in March 2026. Returns for the year ending March 31, 2026 are still filed under the old Act, and your Indian CA confirms which provisions apply to each period.
Which tax year and filing deadlines apply to individuals?
| Event | United States | Canada | India (FY 2025-26) |
|---|---|---|---|
| Usual filing date | April 15, 2026 | April 30, 2026 | July 31, 2026 is the statutory date for individuals without audit; confirm any extension |
| Self-employed or business owner | April 15, 2026 | June 15, 2026 to file; balance due April 30 | Without audit, the individual date; with a tax audit, October 31, 2026, extended to November 21, 2026 |
| Extension | Form 4868 gives six months to file (October 15); tax is still due April 15 | None for the return; interest runs on late payment | CBDT sometimes extends dates by notification |
| Living abroad | Automatic two months, generally June 15, to file and pay, with interest from April 15 | Not applicable | Not applicable |
| Nonresident without wages subject to withholding | June 15 (Form 1040-NR) | April 30 for most non-residents | NRIs follow the same ITR dates as residents |
| Foreign accounts | FBAR: April 15, with an automatic extension to October 15 | T1135: with the T1 return | Schedule FA: part of the ITR |
A few notes on the table. The IRS says a U.S. return extension "is not an extension of time to pay", and that taxpayers abroad still owe interest on tax unpaid by the original date. The Canada Revenue Agency lists April 30, 2026 as the date to file and to pay, with June 15, 2026 as the filing date for self-employed people and their spouses. In India, the CBDT moved the audit-case return date for assessment year 2026-27 from October 31 to November 21, 2026, and the audit report date from September 30 to October 21, 2026, according to a Press Information Bureau release dated September 28, 2026. Dates are sometimes moved for everyone, so check the portal calendar for the year you are filing.
Business and other recurring dates
| Item | United States | Canada | India |
|---|---|---|---|
| Partnerships and S corporations | March 16, 2026 for 2025 (calendar-year) | Partnership information return rules differ; confirm with your CPA | Firms and LLPs file by the audit or non-audit dates |
| C corporations / companies | April 15 for calendar-year filers | Six months after year-end; balance due two months after year-end, or three months for a qualifying CCPC | Audit cases for AY 2026-27 were due November 21, 2026 after extension |
| Quarterly payroll return | Form 941: April 30, July 31, October 31, January 31 | Remittance by the 15th of the next month for regular remitters | Monthly deposits and quarterly returns, set by the CA |
| Employee slips | W-2 and 1099-NEC: January 31 | T4: last day of February | Salary certificates are issued annually |
| Installments | Four estimated-tax payment periods | Installments during the year when tax owing exceeds the CRA's threshold | Advance tax: June 15, September 15, December 15, March 15 |
The Canadian and Indian business dates above come from the CRA's corporation guidance and from the Indian tax department's advance tax rules, which the department says are unchanged under the 2025 Act. When a due date falls on a weekend or holiday, the IRS and the CRA both treat a filing or payment on the next business day as on time.
Practical consequences for people in more than one country
- The years straddle. India's FY 2025-26 covers January through March 2026, which belongs to U.S. tax year 2026. Rent or interest earned in those months is reported in different years on each side.
- Foreign tax credits are timed differently. The U.S. return for 2025 is due before an Indian return for FY 2025-26 may be finalized, so a U.S. credit may need to be claimed on an estimated or amended basis. See foreign tax credits across three countries.
- Penalties are separate. A late FBAR, a late T1135 and an unfiled Schedule FA each have their own consequences.
- Extensions do not carry over. A U.S. extension does not move the Canadian or Indian date.
A worked example
Anjali lives in Naperville, owns a flat in Pune and has a Toronto RRSP from earlier work. For 2025 her calendar looks like this: March 31, 2026, India's financial year ends; April 15, 2026, her U.S. return, FBAR and any tax due; June 15, 2026, the first Indian advance tax instalment for the new financial year; July 31, 2026, her Indian return; and October 15, 2026, the outer limit if she filed a U.S. extension. Her Canadian filing is not required unless she has Canadian income, but any Canadian-source income would follow the April 30 date. She asks us to keep the three dates in one calendar and to confirm the Indian dates with her CA. Her Indian tax for FY 2025-26 is not final on April 15, so we compute the U.S. credit conservatively and revisit it once the Indian return is filed.
Mistakes to avoid
- Treating "2025" as one period in all three countries.
- Assuming a U.S. extension also extends payment, or that it covers the FBAR separately (the FBAR has its own automatic extension).
- Using last year's Indian due date without checking whether it was extended.
- Calling Indian income "FY 2026" without saying which year; use "FY 2025-26" and "tax year 2026-27".
- Missing the Canadian June 15 versus April 30 payment difference for self-employed people.
How we can help
Our Aurora, Illinois firm prepares the U.S. side and coordinates with your Canadian CPA and Indian CA so deadlines, credits and reports line up. See cross-border tax services, foreign account and asset reporting and relocation and immigration tax planning, and read the October 2026 deadlines update. More three-country tables are on the comparisons hub.
Frequently asked questions
What is India's tax year called?
Under the 1961 Act the income year is the financial year (for example 2025-26) and the filing year is the assessment year (2026-27). The 2025 Act uses "tax year" for periods from April 1, 2026.
Is the October 15 U.S. deadline an extension of time to pay?
No. It extends the time to file only. Tax is still due April 15, and interest runs on late payments.
Does Canada have an automatic extension like the U.S.?
Not for the T1 return. The June 15 date applies to self-employed people and their spouses, and the balance is still due April 30.
Can I file my Indian return later because I live in the U.S.?
No. NRIs follow the same return dates as residents, unless the CBDT extends them for everyone. Your Indian CA tracks the dates.
When is the FBAR due?
April 15 after the calendar year, with an automatic extension to October 15. See the FBAR guide and the US federal tax calendar.
Official sources
- IRS: Topic no. 304, Extensions of time to file
- IRS: Taxation of nonresident aliens
- FinCEN and IRS: Report of Foreign Bank and Financial Accounts
- CRA: Due dates and payment dates for personal income tax
- PIB: CBDT extends return due date for AY 2026-27 audit cases
- PIB: Income-tax Act, 2025 comes into force
This page summarizes public guidance in plain language. If anything here differs from the official source, the official source controls.
General information only. It is not tax, legal, accounting or immigration advice for your situation, and rules change; confirm the current rules with the official source or a licensed professional in the relevant country.