Internal Revenue Code · 26 U.S.C.
§ 6114. Treaty-based return positions
Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).
Cite as 26 U.S.C. § 6114
At a glance
Read from the text, the source credit and the official notes. Not part of the law.
- Status
- In force
- Added
- November 10, 1988 by Pub. L. 100–647
- Last amended
- November 5, 1990 by Pub. L. 101–508
- Amendments
- 1 dated changes in the source credit
- Length
- 2 subsections · 148 words · about 1 min to read
- Cross-references
- cites 0; cited by 1 Code section and 6 other regulations
- Regulations
- 1 issued under this section
(Added Pub. L. 100–647, title I, § 1012(aa)(5)(A), Nov. 10, 1988, 102 Stat. 3532; amended Pub. L. 101–508, title XI, § 11702(c), Nov. 5, 1990, 104 Stat. 1388–514.)
Regulations under this section
Treasury regulations (26 CFR) issued under § 6114
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
Cited by 1 Code section
Cited in 6 regulations not issued under it
- § 1.1298-1 Section 1298(f) annual reporting requirements for United States persons that are shareholders of a passive foreign investment company.
- § 1.6038A-1 General requirements and definitions.
- § 1.6038D-2 Requirement to report specified foreign financial assets.
- § 301.6712-1 Failure to disclose treaty-based return positions.
- § 301.7701(b)-0 Outline of regulation provision for section 7701(b)-1 through (b)-9.
- § 301.7701(b)-7 Coordination with income tax treaties.
Amendment history
From the source credit and the official notes, newest first.
- Amended by Pub. L. 101–508Parts changed in 1990: (b)
- Added by Pub. L. 100–647
Where it sits in the Code
- Subtitle F Procedure and Administration
- Chapter 61 INFORMATION AND RETURNS
- Subchapter B Miscellaneous Provisions
Nearby sections
- § 6110 Public inspection of written determinations
- § 6111 Disclosure of reportable transactions
- § 6112 Material advisors of reportable transactions must keep lists of advisees, etc.
- § 6113 Disclosure of nondeductibility of contributions
- § 6114 Treaty-based return positions
- § 6115 Disclosure related to quid pro quo contributions
- § 6116 Requirement for prisons located in United States to provide information for tax administration
- § 6117 Cross reference
Official notes
Show the Law Revision Counsel's notes (amendments, effective dates)
Editorial Notes
Prior Provisions
A prior section 6114 was renumbered 6116 of this title.
Amendments
1990—Subsec. (b). Pub. L. 101–508 struck out “by regulations” before “waive the requirements”.
Statutory Notes and Related Subsidiaries
Effective Date of 1990 Amendment
Amendment by Pub. L. 101–508 effective as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 11702(j) of Pub. L. 101–508, set out as a note under section 59 of this title.
Effective Date
Pub. L. 100–647, title I, § 1012(aa)(5)(D), Nov. 10, 1988, 102 Stat. 3533, provided that: “The amendments made by this paragraph [enacting this section and section 6712 of this title and renumbering former section 6114 as section 6115 of this title] shall apply to taxable periods the due date for filing returns for which (without extension) occurs after December 31, 1988.”