26 U.S.C. § 6712

Current through P.L. 118-59 (published on www.congress.gov on 05/07/2024)

Section 6712 - Failure to disclose treaty-based return positions

(a) General rule

If a taxpayer fails to meet the requirements of section 6114, there is hereby imposed a penalty equal to $1,000 ($10,000 in the case of a C corporation) on each such failure.

(b) Authority to waive

The Secretary may waive all or any part of the penalty provided by this section on a showing by the taxpayer that there was reasonable cause for the failure and that the taxpayer acted in good faith.

(c) Penalty in addition to other penalties

The penalty imposed by this section shall be in addition to any other penalty imposed by law.

26 U.S.C. § 6712

Added Pub. L. 100-647, title I, §1012(aa)(5)(B), Nov. 10, 1988, 102 Stat. 3532.

EDITORIAL NOTES

CODIFICATIONAnother section 6712 was renumbered section 6713 of this title.

STATUTORY NOTES AND RELATED SUBSIDIARIES

EFFECTIVE DATESection applicable to taxable periods the due date for filing returns for which (without extension) occurs after Dec. 31, 1988, see section 1012(aa)(5)(D) of Pub. L. 100-647 set out as a note under section 6114 of this title.

Secretary

The term "Secretary" means the Secretary of the Treasury or his delegate.

corporation

The term "corporation" includes associations, joint-stock companies, and insurance companies.

taxpayer

The term "taxpayer" means any person subject to any internal revenue tax.