Tax Notes logo
HOMETAX NOTES RESEARCHFEDERALINTERNAL REVENUE CODE OF 1986

Sec. 6712 Failure to disclose treaty-based return positions

  • Internal Revenue Code of 1986
  • SUBTITLE F -- PROCEDURE AND ADMINISTRATION
  • Chapter 68 -- Additions to the Tax, Additional Amounts, and Assessable Penalties
  • Subchapter B -- Assessable Penalties
  • Part I -- General provisions

(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.

Copy RID