§ 6712. Failure to disclose treaty-based return positions

172 words·~1 min read·/usc/title-26/section-6712

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(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.

(Added Pub. L. 100–647, title I, § 1012(aa)(5)(B), Nov. 10, 1988, 102 Stat. 3532.)

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U.S. Code

statutes-at-large

Public Law 100–647
To make technical corrections relating to the Tax Reform Act of 1986, and for other purposes

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U.S. Code

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Pub. L. 100–647, title I, § 1012(aa)(5)(B)
102 Stat. 3532
section 1012(aa)(5)(D) of Pub. L. 100–647

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cites case law

§ 6712

Failure to disclose treaty-based return positions

U.S.C.×2

Stat.×1

U.S.C.§ 6713

U.S.C.§ 6114

Pub. L.Pub. L. 100–647, title I, § 1012(aa)(5)(B)

Stat.102 Stat. 3532

Pub. L.section 1012(aa)(5)(D) of Pub. L. 100–647

Cites 5Cited by 3 across 2 sources