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SECTION 12. INTERNATIONAL ISSUES—CONTINUED

Internal Revenue Bulletin 2001-47 · 2026-10-03 edition · updated 2026-10-04 · United States

Statute or
Regulation
Act Postponed
41.

Sec.
6038A(d)(2)
and Treas.
Reg.
§ 1.6038A-
4(d)(1)
A reporting corporation must cure any failure to furnish information or failure to maintain
records before the beginning of each 30-day period after expiration of the initial 90-day
period to avoid additional continuation penalties.
42.

Sec.
6038A(e)(1)
and Treas.
Reg.
§ 1.6038A-
5(b)
A reporting corporation must furnish an authorization of agent within 30 days of a request
by the IRS to avoid a penalty.
43.

Sec.
6038A(e)(4)
(A)
A reporting corporation must commence any proceeding to quash a summons filed by the
IRS in connection with an information request within 90 days of the date the summons is
issued.
44.
Sec.
6038A(e)
(4)(B)
A reporting corporation must commence any proceeding to review the IRS’s determination
of noncompliance with a summons within 90 days of the IRS’s notice of noncompliance.
45.
Sec. 6038A
and Treas.
Reg.
§ 1.6038A-
3(b)(3)
A reporting corporation must supply an English translation of records provided pursuant to
a request for production within 30 days of a request by the IRS for a translation to avoid a
penalty.
46.

Sec. 6038A
and Treas.
Reg.
§ 1.6038A-
3(f)(2)
A reporting corporation must, within 60 days of a request by the IRS for records main-
tained outside the United States, either provide the records to the IRS, or move them to the
United States and provide the IRS with an index to the records to avoid a penalty.
47.

Sec. 6038A
and Treas.
Reg.
§ 1.6038A-
3(f)(2)(i)
A reporting corporation must supply English translations of documents maintained outside
the United States within 30 days of a request by the IRS for translation to avoid a penalty.
48.

Sec. 6038A
and Treas.
Reg.
§ 1.6038A-
3(f)(4)
A reporting corporation must request an extension of time to produce or translate docu-
ments maintained outside the United States beyond the period specified in the regulations
within 30 days of a request by the IRS to avoid a penalty.
49.

Sec. 6662(e)
and Treas.
Reg.
§ 1.6662-
6(d)(2)(iii)(A)
A taxpayer must provide, within 30 days of a request by the IRS, specified “principal
documents” regarding the taxpayer’s selection and application of transfer pricing method to
avoid potential penalties in the event of a final transfer pricing adjustment by the IRS.See
also Treas. Reg. § 1.6666-6(d)(2)(iii)(C) (similar requirement re: background documents).
50.
Secs. 6038,
6038B, and
6046A
The filing of Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partner-
ships, for those taxpayers who do not have to file an income tax return. The form is due at
the time that an income tax return would have been due had the taxpayer been required to
file an income tax return.

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