§ 6114 Treaty-based return positions

OLRC 119-134 · eCFR 2026-10-19 · 1 regs · 1 amending Acts · cited by 1 sections

Enacted 1988 · Pub. L. 100-647 Amended · 1 Acts

Prior provisions 1
  • A prior section 6114 was renumbered 6116 of this title.
Connections Cited by 1 · Cites 0

(a) In general Each taxpayer who, with respect to any tax imposed by this title, takes the position that a treaty of the United States overrules (or otherwise modifies) an internal revenue law of the United States shall disclose (in such manner as the Secretary may prescribe) such position—

Cited by 3

    (1) on the return of tax for such tax (or any statement attached to such return), or

    (2) if no return of tax is required to be filed, in such form as the Secretary may prescribe.

    (b) Waiver authority The Secretary may waive the requirements of subsection (a) with respect to classes of cases for which the Secretary determines that the waiver will not impede the assessment and collection of tax.

    Amended 1990
    • 1990 Pub. L. 101-508 Pub. L. 101–508 struck out “by regulations” before “waive the requirements”.