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.