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Internal Revenue Code · 26 U.S.C.

§ 6712. Failure to disclose treaty-based return positions

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. § 6712

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
Length
3 subsections · 115 words · about 1 min to read
(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.)

Regulations under this section

Treasury regulations (26 CFR) issued under § 6712

Cross-references

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

This section cites 1 other section

Cited in 2 regulations not issued under it

Amendment history

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

  1. Added by Pub. L. 100–647

Where it sits in the Code

  1. Subtitle F Procedure and Administration
  2. Chapter 68 ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES
  3. Subchapter B Assessable Penalties
  4. Part I GENERAL PROVISIONS

Nearby sections

Official notes

Show the Law Revision Counsel's notes (amendments, effective dates)

Editorial Notes

Codification

Another section 6712 was renumbered section 6713 of this title.

Effective Date

Section applicable to taxable periods the due date for filing returns for which (without extension) occurs after Dec. 31, 1988, see section 1012(aa)(5)(D) of Pub. L. 100–647, set out as a note under section 6114 of this title.