Internal Revenue Code · 26 U.S.C.
§ 6707. Failure to furnish information regarding reportable transactions
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. § 6707
At a glance
Read from the text, the source credit and the official notes. Not part of the law.
- Status
- In force
- Added
- July 18, 1984 by Pub. L. 98–369
- Last amended
- October 22, 2004 by Pub. L. 108–357
- Amendments
- 3 dated changes in the source credit
- Length
- 4 subsections · 294 words · about 1 min to read
- Cross-references
- cites 2; cited by 0 Code sections and 4 other regulations
- Regulations
- 1 issued under this section
The provisions of section 6707A(d) (relating to authority of Commissioner to rescind penalty) shall apply to any penalty imposed under this section.
For purposes of this section, the terms “reportable transaction” and “listed transaction” have the respective meanings given to such terms by section 6707A(c).
(Added Pub. L. 98–369, div. A, title I, § 141(b), July 18, 1984, 98 Stat. 680; amended Pub. L. 99–514, title XV, §§ 1532(a), 1533(a), Oct. 22, 1986, 100 Stat. 2750; Pub. L. 105–34, title X, § 1028(b), (d), Aug. 5, 1997, 111 Stat. 927, 928; Pub. L. 108–357, title VIII, § 816(a), Oct. 22, 2004, 118 Stat. 1583.)
Regulations under this section
Treasury regulations (26 CFR) issued under § 6707
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
This section cites 2 other sections
- § 6111(a) Disclosure of reportable transactions
- § 6707A(d) Penalty for failure to include reportable transaction information with return
Cited in 4 regulations not issued under it
- § 1.6664-2 Underpayment.
- § 301.6011-14 Required use of electronic form or other machine-readable form for material advisor disclosure statements.
- § 301.6111-3 Disclosure of reportable transactions.
- § 301.6707A-1 Failure to include on any return or statement any information required to be disclosed under section 6011 with respect to a reportable transaction.
Amendment history
From the source credit and the official notes, newest first.
Where it sits in the Code
- Subtitle F Procedure and Administration
- Chapter 68 ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES
- Subchapter B Assessable Penalties
- Part I GENERAL PROVISIONS
Nearby sections
- § 6703 Rules applicable to penalties under sections 6700, 6701, and 6702
- § 6704 Failure to keep records necessary to meet reporting requirements under section 6047(d)
- § 6705 Failure by broker to provide notice to payors
- § 6706 Original issue discount information requirements
- § 6707 Failure to furnish information regarding reportable transactions
- § 6707A Penalty for failure to include reportable transaction information with return
- § 6708 Failure to maintain lists of advisees with respect to reportable transactions
- § 6709 Penalties with respect to mortgage credit certificates
- § 6710 Failure to disclose that contributions are nondeductible
Official notes
Show the Law Revision Counsel's notes (amendments, effective dates)
Editorial Notes
Amendments
2004—Pub. L. 108–357 amended section catchline and text generally, substituting provisions relating to penalty for failure to furnish information regarding reportable transactions for provisions relating to penalty for failure to furnish information regarding tax shelters.
1997—Subsec. (a)(1). Pub. L. 105–34, § 1028(d)(2), which directed the substitution of “paragraph (2) or (3), as the case may be” for “paragraph (2)” in subpar. (A) of par. (1), was executed by making the substitution in the concluding provisions of par. (1) to reflect the probable intent of Congress.
Subsec. (a)(2). Pub. L. 105–34, § 1028(d)(1), substituted “Except as provided in paragraph (3), the penalty” for “The penalty”.
Subsec. (a)(3). Pub. L. 105–34, § 1028(b), added par. (3).
1986—Subsec. (a)(2). Pub. L. 99–514, § 1532(a), amended par. (2) generally. Prior to amendment, par. (2) read as follows: “The penalty imposed under paragraph (1) with respect to any tax shelter shall be an amount equal to the greater of—
“(A) $500, or
“(B) the lesser of (i) 1 percent of the aggregate amount invested in such tax shelter, or (ii) $10,000.
The $10,000 limitation in subparagraph (B) shall not apply where there is an intentional disregard of the requirements of section 6111(a).”
Subsec. (b)(2). Pub. L. 99–514, § 1533(a), substituted “$250” for “$50”.
Statutory Notes and Related Subsidiaries
Effective Date of 2004 Amendment
Pub. L. 108–357, title VIII, § 816(c), Oct. 22, 2004, 118 Stat. 1584, provided that: “The amendments made by this section [amending this section] shall apply to returns the due date for which is after the date of the enactment of this Act [Oct. 22, 2004].”
Effective Date of 1997 Amendment
Amendment by Pub. L. 105–34 applicable to any tax shelter, as defined in section 6111(d) of this title, interests in which are offered to potential participants after Secretary of the Treasury prescribes guidance with respect to meeting requirements added by amendments made by Pub. L. 105–34, § 1028, see section 1028(e) of Pub. L. 105–34, set out as a note under section 6111 of this title.
Effective Date of 1986 Amendment
Pub. L. 99–514, title XV, § 1532(b), Oct. 22, 1986, 100 Stat. 2750, provided that: “The amendment made by this section [amending this section] shall apply to failures with respect to tax shelters interests in which are first offered for sale after the date of the enactment of this Act [Oct. 22, 1986].”
Pub. L. 99–514, title XV, § 1533(b), Oct. 22, 1986, 100 Stat. 2750, provided that: “The amendment made by this section [amending this section] shall apply to returns filed after the date of the enactment of this Act [Oct 22, 1986].”
Effective Date
Section applicable to tax shelters (within the meaning of section 6111 of this title), any interest in which is first sold to any investor after Aug. 31, 1984, see section 141(d) of Pub. L. 98–369, set out as a note under section 6111 of this title.