26 U.S.C. § 6712
Failure to disclose treaty-based return positions
United States · Title 26 — INTERNAL REVENUE CODE · Status: effective
Cite this
- Citation
- 26 U.S.C. § 6712, Failure to disclose treaty-based return positions, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/464287
- Permanent ID
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Full text
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.
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