Skip to content

CHAPTER 68— ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES›Subchapter B— Assessable Penalties›PART I— GENERAL PROVISIONS

§ 6712. Failure to disclose treaty-based return positions

26 U.S.C. Subtitle F — Procedure and Administration (Internal Revenue Code) · 2026 edition · updated 2026-10-03 · United States

(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.

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

Get a plain-English answer with a citation back to this text.

Ask AI about this code
▸Contents — 26 U.S.C. Subtitle F — Procedure and Administration (Internal Revenue Code)

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.