§ 6712 Failure to disclose treaty-based return positions

OLRC 119-134 · eCFR 2026-10-19 · 1 regs

Enacted 1988 · Pub. L. 100-647 Amended · 0 Acts

Connections Cited by 0 · Cites 1
    § 6712 Failure to disclose treaty-based return positions

    (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.

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      (c) Penalty in addition to other penalties The penalty imposed by this section shall be in addition to any other penalty imposed by law.