Failure to file information with respect to certain foreign trusts

In addition to any criminal penalty provided by law, if any notice or return required to be filed by section 6048— In the case of a return required under section 6048(b)— For purposes of subsection (a), the term “gross reportable amount” means— No penalty shall be imposed by this section on any failure which is shown to be due to reasonable cause and not due to willful neglect. The fact that a foreign jurisdiction would impose a civil or criminal penalty on the taxpayer (or any other person) for disclosing the required information is not reasonable cause. Subchapter B of chapter 63 (relating to deficiency procedures for income, estate, gift, and certain excise taxes) shall not apply in respect of the assessment or collection of any penalty imposed by subsection (a).