2017 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. 6689 - Failure to file notice of redetermination of foreign tax
| 26 U.S.C. § 6689 (2017) |
| §6689. Failure to file notice of redetermination of foreign tax |
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(a) Civil penalty
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— (1) 5 percent of the deficiency if the failure is for not more than 1 month, with (2) an additional 5 percent of the deficiency for each month (or fraction thereof) during which the failure continues. For purposes of this section, the term "foreign tax redetermination" means any redetermination for which a notice is required under subsection (c) of section 905 or paragraph (2) of section 404A(g). |
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(Added Pub. L. 96–603, §2(c)(2), Dec. 28, 1980, 94 Stat. 3509.) |
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PRIOR PROVISIONS
A prior section 6689, added Pub. L. 93–17, §3(d)(2), Apr. 10, 1973, 87 Stat. 16, related to failure by certain foreign issuers and obligors to comply with United States investment equalization tax requirements, prior to repeal by Pub. L. 94–455, title XIX, §1904(b)(10)(E)(i), Oct. 4, 1976, 90 Stat. 1817. EFFECTIVE DATEFor applicability of section with respect to employer contributions or accruals for taxable years beginning after Dec. 31, 1979, election to apply amendments retroactively with respect to foreign subsidiaries, allowance of prior deductions in case of certain funded branch plans, and time and manner for making elections, see section 2(e) of Pub. L. 96–603, set out as a note under section 404A of this title. |
| United States Code, 2012 Edition, Supplement 5, Title 26 - INTERNAL REVENUE CODE |
| Bills and Statutes |
| United States Code |
| Y 1.2/5: |
| 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. 6689 - Failure to file notice of redetermination of foreign tax |
| section 6689 |
| 2017 |
| January 12, 2018 |
| No |
| standard |
| 87 Stat. 16 90 Stat. 1817 94 Stat. 3509 |
| Public Law 93-17, Public Law 94-455, Public Law 96-603 |
