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
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.
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—
5 percent of the deficiency if the failure is for not more than 1 month, with
an additional 5 percent of the deficiency for each month (or fraction thereof) during which the failure continues.
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.)
- 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
no arguments yet — make the first case