FBAR Willfulness, Recklessness, and the Excessive Fines Defense: Key Takeaways from United States v. Rund
Foreign bank account reporting under 31 U.S.C. § 5314 continues to represent a high-stakes area of international tax controversy. Earlier this month, in United States v. Rund (4th Cir. Sept. 4, 2026), the Fourth Circuit