26 U.S.C. § 6712 — Failure to disclose treaty-based return positions
submitted 38 years ago by Pub. L. 100-647 to r/title-26-INTERNAL-REVENUE-CODE · 100 words · no verdicts yet
A taxpayer that fails to meet section 6114’s requirements owes a penalty for each failure. The Secretary may waive all or part of the penalty for reasonable cause and good faith, and the penalty is added to any other penalty required by law.
(a) General rule. If a taxpayer* does not meet section 6114’s requirements, the taxpayer owes a $1,000 penalty for each failure. The penalty is $10,000 for a C corporation*.
(b) Authority to waive. The Secretary* may waive all or part of the penalty if the taxpayer shows that there was reasonable cause for the failure and that the taxpayer acted in good faith.
(c) Penalty in addition to other penalties. This penalty is added to any other penalty imposed by law.
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.
Source credit: (Added Pub. L. 100–647, title I, § 1012(aa)(5)(B), Nov. 10, 1988, 102 Stat. 3532.)
- 1988Enacted · Pub. L. 100-647 · 102 Stat. 3532
A history note hasn’t been published yet. The record shows enactment by Pub. L. 100-647 on 1988-11-10.
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