Statute · United States Code

26 U.S.C. § 6712 — Failure to disclose treaty-based return positions

26 U.S.C. § 6712

Type
Statute
Source
United States Code
Jurisdiction
Federal
Date
2026-10-22

(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.

Citator

26 U.S.C. § 6712 — Failure to disclose treaty-based return positions is in force in the current edition of the Code, and nothing recorded condemns it.

(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.