2012 US Code
Title 26 - Internal Revenue Code
Subtitle F - Procedure and Administration (§§ 6001 - 7874)
Chapter 68 - ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES (§§ 6651 - 6751)
Subchapter B - Assessable Penalties (§§ 6671 - 6725)
Part I - GENERAL PROVISIONS (§§ 6671 - 6720C)
Section 6712 - Failure to disclose treaty-based return positions

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Metadata
Publication TitleUnited States Code, 2012 Edition, Title 26 - INTERNAL REVENUE CODE
CategoryBills and Statutes
CollectionUnited States Code
SuDoc Class NumberY 1.2/5:
Contained WithinTitle 26 - INTERNAL REVENUE CODE
Subtitle F - Procedure and Administration
CHAPTER 68 - ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES
Subchapter B - Assessable Penalties
PART I - GENERAL PROVISIONS
Sec. 6712 - Failure to disclose treaty-based return positions
Containssection 6712
Date2012
Laws in Effect as of DateJanuary 15, 2013
Positive LawNo
Dispositionstandard
Source CreditAdded Pub. L. 100-647, title I, §1012(aa)(5)(B), Nov. 10, 1988, 102 Stat. 3532.
Statutes at Large Reference102 Stat. 3532
Public Law ReferencesPublic Law 100-647

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GENERAL PROVISIONS - 26 U.S.C. § 6712 (2012)
§6712. Failure to disclose treaty-based return positions (a) General rule

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.

(b) Authority to waive

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.

(c) Penalty in addition to other penalties

The penalty imposed by this section shall be in addition to any other penalty imposed by law.

(Added Pub. L. 100–647, title I, §1012(aa)(5)(B), Nov. 10, 1988, 102 Stat. 3532.)

Codification

Another section 6712 was renumbered section 6713 of this title.

Effective Date

Section applicable to taxable periods the due date for filing returns for which (without extension) occurs after Dec. 31, 1988, see section 1012(aa)(5)(D) of Pub. L. 100–647, set out as a note under section 6114 of this title.

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