# 26 U.S.C. § 6726: Failure to comply with information reporting requirements relating to qualified opportunity funds and qualified rural opportunity funds

Source: OLRC release point 119-134 <https://uscode.house.gov/us/usc/119-134/t26/s6726>. Cite pinpoints as 26 U.S.C. § 6726(a)(1).

## § 6726(a) In general

If any person required to file a return under section 6039K fails to file a complete and correct return under such section in the time and in the manner prescribed therefor, such person shall pay a penalty of $500 for each day during which such failure continues.

## § 6726(b) Limitation

**§ 6726(b)(1) In general.** The maximum penalty under this section on failures with respect to any 1 return shall not exceed $10,000.

**§ 6726(b)(2) Large qualified opportunity funds.** In the case of any failure described in subsection (a) with respect to a fund the gross assets of which (determined on the last day of the taxable year) are in excess of $10,000,000, paragraph (1) shall be applied by substituting “$50,000” for “$10,000”.

## § 6726(c) Penalty in cases of intentional disregard

If a failure described in subsection (a) is due to intentional disregard, then—

**§ 6726(c)(1)** subsection (a) shall be applied by substituting “$2,500” for “$500”,

**§ 6726(c)(2)** subsection (b)(1) shall be applied by substituting “$50,000” for “$10,000”, and

**§ 6726(c)(3)** subsection (b)(2) shall be applied by substituting “$250,000” for “$50,000”.

## § 6726(d) Inflation adjustment

**§ 6726(d)(1) In general.** In the case of any failure relating to a return required to be filed in a calendar year beginning after 2025, each of the dollar amounts in subsections (a), (b), and (c) shall be increased by an amount equal to—

**§ 6726(d)(1)(A)** such dollar amount, multiplied by

**§ 6726(d)(1)(B)** the cost-of-living adjustment determined under section 1(f)(3) for the calendar year determined by substituting “calendar year 2024” for “calendar year 2016” in subparagraph (A)(ii) thereof.

**§ 6726(d)(2) Rounding.**

**§ 6726(d)(2)(A) In general.** If the $500 dollar amount in subsection (a) and (c)(1) or the $2,500 amount in subsection (c)(1), after being increased under paragraph (1), is not a multiple of $10, such dollar amount shall be rounded to the next lowest multiple of $10.

**§ 6726(d)(2)(B) Asset threshold.** If the $10,000,000 dollar amount in subsection (b)(2), after being increased under paragraph (1), is not a multiple of $10,000, such dollar amount shall be rounded to the next lowest multiple of $10,000.

**§ 6726(d)(2)(C) Other dollar amounts.** If any dollar amount in subsection (b) or (c) (other than any amount to which subparagraph (A) or (B) applies), after being increased under paragraph (1), is not a multiple of $1,000, such dollar amount shall be rounded to the next lowest multiple of $1,000.

## Proposed regulations (not in force)

- [Prop. Treas. Reg. § 301.6726-1](/26/prop/301.6726-1_2026-18574.md): Failure to comply with information reporting requirements relating to qualified opportunity funds and qualified rural opportunity funds. (REG-115420-18, proposed 2026-09-11)

## Connections

Cites: § 1 Tax imposed; § 6039K Returns with respect to qualified opportunity funds and qualified rural opportunity funds

Cited by: none

## Amendments

- 2025-07-04: [Pub. L. 119-21](/26/act/119-21.md), 139 Stat. 230