Internal Revenue Code · 26 U.S.C.

§ 6689. Failure to file notice of redetermination of foreign tax

In force Text current through Public Law 119-121 (October 9, 2026) release point 119-121

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. § 6689

At a glance

Read from the text, the source credit and the official notes. Not part of the law.

Status: In force
Added: December 28, 1980 by Pub. L. 96–603
Length: 2 subsections · 157 words · about 1 min to read
Defines: 1 term
Cross-references: cites 2; cited by 0 Code sections and 1 other regulation
Regulations: 1 issued under this section

¶(a) Civil penalty If the taxpayer fails to notify the Secretary (on or before the date prescribed by regulations for giving such notice) of a foreign tax redetermination, unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the deficiency attributable to such redetermination an amount (not in excess of 25 percent of the deficiency) determined as follows—

¶(1) 5 percent of the deficiency if the failure is for not more than 1 month, with

¶(2) an additional 5 percent of the deficiency for each month (or fraction thereof) during which the failure continues.

¶(b) Foreign tax redetermination defined

For purposes of this section, the term “foreign tax redetermination” means any redetermination for which a notice is required under subsection (c) of section 905 or paragraph (2) of section 404A(g).

(Added Pub. L. 96–603, § 2(c)(2), Dec. 28, 1980, 94 Stat. 3509.)

Terms defined here

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foreign tax redetermination § 6689(b)

Regulations under this section

Treasury regulations (26 CFR) issued under § 6689

§ 301.6689-1 Failure to file notice of redetermination of foreign income taxes.

Cross-references

Computed from the citations in the text of Title 26 and 26 CFR.

This section cites 2 other sections

Cited in 1 regulation not issued under it

§ 1.905-4 Notification of foreign tax redetermination.

Amendment history

From the source credit and the official notes, newest first.

December 28, 1980Added by Pub. L. 96–603

Where it sits in the Code

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Official notes

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Editorial Notes

Prior Provisions

A prior section 6689, added Pub. L. 93–17, § 3(d)(2), Apr. 10, 1973, 87 Stat. 16, related to failure by certain foreign issuers and obligors to comply with United States investment equalization tax requirements, prior to repeal by Pub. L. 94–455, title XIX, § 1904(b)(10)(E)(i), Oct. 4, 1976, 90 Stat. 1817.

Effective Date

For applicability of section with respect to employer contributions or accruals for taxable years beginning after Dec. 31, 1979, election to apply amendments retroactively with respect to foreign subsidiaries, allowance of prior deductions in case of certain funded branch plans, and time and manner for making elections, see section 2(e) of Pub. L. 96–603, set out as a note under section 404A of this title.