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
2025-01-06
Topic
bankruptcy

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

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