# 26 U.S.C. § 6712: Failure to disclose treaty-based return positions

Source: OLRC release point 119-134 <https://uscode.house.gov/us/usc/119-134/t26/s6712>. Cite pinpoints as 26 U.S.C. § 6712(a)(1).

## § 6712(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.

## § 6712(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.

## § 6712(c) Penalty in addition to other penalties

The penalty imposed by this section shall be in addition to any other penalty imposed by law.

## Regulations

- [Treas. Reg. § 301.6712-1](/26/reg/301.6712-1.md): Failure to disclose treaty-based return positions. (interprets § 6712)

## Connections

Cites: § 6114 Treaty-based return positions

Cited by: none

## Amendments

- 1988-11-10: [Pub. L. 100-647](/26/act/100-647.md), 102 Stat. 3532