ALLcrimesfood&drugstaxestelecomcommercehealthconservationtransportationagricultureveteransbrowse all titles »
0

26 U.S.C. § 6689 — Failure to file notice of redetermination of foreign tax

submitted 46 years ago by Pub. L. 96-603 to r/title-26-INTERNAL-REVENUE-CODE · 143 words · no verdicts yet

in plain englishAI-generated · not legal advice

A taxpayer who fails to notify the Secretary of a foreign tax redetermination may have up to 25 percent added to the resulting deficiency. The amount starts at 5 percent and increases by another 5 percent for each continuing month or part of a month.

(a) Civil penalty. Unless reasonable cause and no willful neglect are shown, failing to notify the Secretary by the regulatory deadline of a foreign tax redetermination adds to the related deficiency an amount capped at 25 percent of that deficiency: (1) 5 percent if the failure lasts no more than one month, plus (2) another 5 percent for each month or part of a month the failure continues. (b) Definition. “Foreign tax redetermination” means a redetermination requiring notice under section 905(c) or section 404A(g)(2). This section does not otherwise define the quoted term.

the actual law source: uscode.house.gov ↗public domain
(a) Civil penalty

If the taxpayer fails to notify the Secretary (on or before the date prescribed by regulations for giving such notice) of a foreign tax redetermination, unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the deficiency attributable to such redetermination an amount (not in excess of 25 percent of the deficiency) determined as follows—

(1)

5 percent of the deficiency if the failure is for not more than 1 month, with

(2)

an additional 5 percent of the deficiency for each month (or fraction thereof) during which the failure continues.

(b) Foreign tax redetermination defined

For purposes of this section, the term “foreign tax redetermination” means any redetermination for which a notice is required under subsection (c) of section 905 or paragraph (2) of section 404A(g).

Source credit: (Added Pub. L. 96–603, § 2(c)(2), Dec. 28, 1980, 94 Stat. 3509.)

history & why it existsrecord from the source credit
  • 1980Enacted · Pub. L. 96-603 · 94 Stat. 3509

A history note hasn’t been published yet. The record shows enactment by Pub. L. 96-603 on 1980-12-28.

all 0 arguments · sorted by: best

0/280

no arguments yet — make the first case