26 U.S.C. § 6114
Treaty-based return positions
United States · Title 26 — INTERNAL REVENUE CODE · Status: effective
Cite this
- Citation
- 26 U.S.C. § 6114, Treaty-based return positions, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/464043
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Full text
Each taxpayer who, with respect to any tax imposed by this title, takes the position that a treaty of the United States overrules (or otherwise modifies) an internal revenue law of the United States shall disclose (in such manner as the Secretary may prescribe) such position—
The Secretary may waive the requirements of subsection (a) with respect to classes of cases for which the Secretary determines that the waiver will not impede the assessment and collection of tax.
Legislative history
The public laws that enacted or amended this section. Tallies are for the whole bill as it passed each chamber — often an omnibus covering far more than this provision — not a vote on this section alone.
- Technical and Miscellaneous Revenue Act of 1988House: no recorded tallySenate: no recorded tally
- Omnibus Budget Reconciliation Act of 1990