§ 6726. Failure to comply with information reporting requirements relating to qualified opportunity funds and qualified rural opportunity funds

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(a)In general If any person required to file a return under section 6039K fails to file a complete and correct return under such section in the time and in the manner prescribed therefor, such person shall pay a penalty of $500 for each day during which such failure continues.

(b)Limitation

(1)In general The maximum penalty under this section on failures with respect to any 1 return shall not exceed $10,000.

(2)Large qualified opportunity funds In the case of any failure described in subsection

(a)with respect to a fund the gross assets of which (determined on the last day of the taxable year) are in excess of $10,000,000, paragraph

(1)shall be applied by substituting “$50,000” for “$10,000”.

(c)Penalty in cases of intentional disregard If a failure described in subsection

(a)is due to intentional disregard, then—

(1)subsection

(a)shall be applied by substituting “$2,500” for “$500”,

(2)subsection (b)(1) shall be applied by substituting “$50,000” for “$10,000”, and

(3)subsection (b)(2) shall be applied by substituting “$250,000” for “$50,000”.

(d)Inflation adjustment

(1)In general In the case of any failure relating to a return required to be filed in a calendar year beginning after 2025, each of the dollar amounts in subsections (a), (b), and

(c)shall be increased by an amount equal to—

(A)such dollar amount, multiplied by

(B)the cost-of-living adjustment determined under section 1(f)(3) for the calendar year determined by substituting “calendar year 2024” for “calendar year 2016” in subparagraph (A)(ii) thereof.

(2)Rounding

(A)In general If the $500 dollar amount in subsection

(a)and (c)(1) or the $2,500 amount in subsection (c)(1), after being increased under paragraph (1), is not a multiple of $10, such dollar amount shall be rounded to the next lowest multiple of $10.

(B)Asset threshold If the $10,000,000 dollar amount in subsection (b)(2), after being increased under paragraph (1), is not a multiple of $10,000, such dollar amount shall be rounded to the next lowest multiple of $10,000.

(C)Other dollar amounts If any dollar amount in subsection

(b)or

(c)(other than any amount to which subparagraph

(A)or

(B)applies), after being increased under paragraph (1), is not a multiple of $1,000, such dollar amount shall be rounded to the next lowest multiple of $1,000.

(Added Pub. L. 119–21, title VII, § 70421(d)(2)(A), July 4, 2025, 139 Stat. 230.)

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