2011 US Code
Title 26 - Internal Revenue Code
Subtitle F - Procedure and Administration (§§ 6001 - 7874)
Chapter 61 - INFORMATION AND RETURNS (§§ 6001 - 6117)
Subchapter B - Miscellaneous Provisions (§§ 6101 - 6117)
Section 6114 - Treaty-based return positions
View MetadataPublication Title | United States Code, 2006 Edition, Supplement 5, Title 26 - INTERNAL REVENUE CODE |
Category | Bills and Statutes |
Collection | United States Code |
SuDoc Class Number | Y 1.2/5: |
Contained Within | Title 26 - INTERNAL REVENUE CODE Subtitle F - Procedure and Administration CHAPTER 61 - INFORMATION AND RETURNS Subchapter B - Miscellaneous Provisions Sec. 6114 - Treaty-based return positions |
Contains | section 6114 |
Date | 2011 |
Laws in Effect as of Date | January 3, 2012 |
Positive Law | No |
Disposition | standard |
Source Credit | Added Pub. L. 100-647, title I, §1012(aa)(5)(A), Nov. 10, 1988, 102 Stat. 3532; amended Pub. L. 101-508, title XI, §11702(c), Nov. 5, 1990, 104 Stat. 1388-514. |
Statutes at Large References | 102 Stat. 3532 104 Stat. 1388-514 |
Public Law References | Public Law 100-647, Public Law 101-508 |
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Each taxpayer who, with respect to any tax imposed by this title, takes the position that a treaty of the United States overrules (or otherwise modifies) an internal revenue law of the United States shall disclose (in such manner as the Secretary may prescribe) such position—
(1) on the return of tax for such tax (or any statement attached to such return), or
(2) if no return of tax is required to be filed, in such form as the Secretary may prescribe.
(b) Waiver authorityThe Secretary may waive the requirements of subsection (a) with respect to classes of cases for which the Secretary determines that the waiver will not impede the assessment and collection of tax.
(Added Pub. L. 100–647, title I, §1012(aa)(5)(A), Nov. 10, 1988, 102 Stat. 3532; amended Pub. L. 101–508, title XI, §11702(c), Nov. 5, 1990, 104 Stat. 1388–514.)
Prior ProvisionsA prior section 6114 was renumbered 6116 of this title.
Amendments1990—Subsec. (b). Pub. L. 101–508 struck out “by regulations” before “waive the requirements”.
Effective Date of 1990 AmendmentAmendment by Pub. L. 101–508 effective as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 11702(j) of Pub. L. 101–508, set out as a note under section 59 of this title.
Effective DateSection 1012(aa)(5)(D) of Pub. L. 100–647 provided that: “The amendments made by this paragraph [enacting this section and section 6712 of this title and renumbering former section 6114 as section 6115 of this title] shall apply to taxable periods the due date for filing returns for which (without extension) occurs after December 31, 1988.”
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