26 U.S.C. § 6689
§ 6689. Failure to file notice of redetermination of foreign tax
No plain-English explainer yet. Below is the official text. Explainers are being added section by section.
The law as written
Current through Public Law 119-102. Amendment notes omitted.
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.