Internal Revenue Code · 26 U.S.C.
§ 6712. Failure to disclose 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. § 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
- Cross-references
- cites 1; cited by 0 Code sections and 2 other regulations
- Regulations
- 1 issued under this section
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.
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.
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.
- Added by Pub. L. 100–647
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
- § 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
- § 6711 Failure by tax-exempt organization to disclose that certain information or service available from Federal Government
- § 6712 Failure to disclose treaty-based return positions
- § 6713 Disclosure or use of information by preparers of returns
- § 6714 Failure to meet disclosure requirements applicable to quid pro quo contributions
- § 6715 Dyed fuel sold for use or used in taxable use, etc.
- § 6715A Tampering with or failing to maintain security requirements for mechanical dye injection systems
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.
Statutory Notes and Related Subsidiaries
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.