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Current Federal Tax Developments · Jan 7, 2026

Second Circuit Joins Sister Circuits: Recklessness Suffices for Willful FBAR Penalties in United States v. Reyes

Tax Brief summary and classification of the original reporting.

Bottom Line

💡 Second Circuit Joins Sister Circuits: Recklessness Suffices for Willful FBAR .... Worth reviewing for potential client impact.

Summary

In a decision solidifying the judicial consensus regarding civil penalties under the Bank Secrecy Act (BSA), the United States Court of Appeals for the Second Circuit recently affirmed a summary judgment ruling in United States v. Reyes. The court held that the statutory term "willfully" encompas...

Classification

Category: fyiPriority: importantReason: Contains 'ruling' - significant update

Applies To

international

Affected Groups

International tax practitioners

Original Source

We aggregate public tax updates and provide AI-assisted summaries. Please read the original reporting for full details.

Read original article