2016 US Code
Title 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

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Citation 26 U.S.C. § 6712 (2016)
Section Name §6712. Failure to disclose treaty-based return positions
Section Text (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.

Source Credit

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

Editorial Notes CODIFICATION

Another section 6712 was renumbered section 6713 of this title.


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.

Publication Title United States Code, 2012 Edition, Supplement 4, 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
Subchapter B - Assessable Penalties
Sec. 6712 - Failure to disclose treaty-based return positions
Contains section 6712
Date 2016
Laws In Effect As Of Date January 6, 2017
Positive Law No
Disposition standard
Statutes at Large Reference 102 Stat. 3532
Public Law References Public Law 100-647
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