U.S. Court of Appeals for 2nd Circuit Affirms FBAR Recklessness/Willfulness Standard

On January 7, 2026, the United States (U.S.) Court of Appeals for the Second Circuit affirmed a summary judgment decision by the U.S. District Court, enforcing willful penalties against U.S. taxpayers. Most importantly, the decision by Judge Lewis J. Liman for the appellate court found the district court did not err in holding that “willful” as used in the statute encompasses reckless conduct.