26 U.S.C. § 6712
§ 6712. Failure to disclose treaty-based return positions
No plain-English explainer yet. Below is the official text. Explainers are being added section by section.
History
Added in 1988 by the Technical and Miscellaneous Revenue Act of 1988. Last changed November 10, 1988 by the Technical and Miscellaneous Revenue Act of 1988.
Every change, newest first (1)
- November 10, 1988Technical and Miscellaneous Revenue Act of 1988 · added this section
The law as written
Current through Public Law 119-102. Amendment notes omitted.
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.