Skip to content
Tax Law Center Blog

Tax Law Center Blog

  • Tax & Foreign Assets
    • Tax Law Services
    • Foreign Asset Planning
  • About
  • Contact Us
Close Button

Day: January 16, 2026

Second Circuit Affirms Recklessness Standard for Willful FBAR Penalties

16 January, 2026

On January 7, 2026, the United States Court of Appeals for the Second Circuit issued its opinion in United States v. Reyes, holding that “willfulness” for purposes of civil FBAR penalties encompasses reckless conduct. For

Read More

Recent Posts

  • The Push to Eliminate Duplicative FBAR and Form 8938 ReportingFebruary 4, 2026
  • Unfortunate Tax Lessons from the Dr. Merchia Fraud ConvictionFebruary 3, 2026
  • The High Cost of Cash: Analyzing the $3 Million Tax Evasion Sentencing of a ContractorFebruary 2, 2026
  • Is Turbotax Reliance a Valid Defense Against IRS Penalties?January 28, 2026
  • New Proposed IRS Voluntary Disclosure Practice (VDP): FAQsJanuary 20, 2026

Pages

  • About Patel Law Offices
  • Delinquent FinCen Form 114 (FBAR) Filings
  • Delinquent or unfiled IRS Form 5471
  • Request A Free Educational Consultation

Law Firm Attorney WordPress Theme By Themespride