2020 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
| 26 U.S.C. § 6712 (2020) |
| §6712. Failure to disclose treaty-based return positions |
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(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 waiveThe 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 penaltiesThe penalty imposed by this section shall be in addition to any other penalty imposed by law. |
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(Added Pub. L. 100–647, title I, §1012(aa)(5)(B), Nov. 10, 1988, 102 Stat. 3532.) |
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CODIFICATION
Another section 6712 was renumbered section 6713 of this title. EFFECTIVE DATESection 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. |
| United States Code, 2018 Edition, Supplement 2, 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. 6712 - Failure to disclose treaty-based return positions |
| section 6712 |
| 2020 |
| January 13, 2021 |
| No |
| standard |
| 102 Stat. 3532 |
| Public Law 100-647 |
