Current through Pub. L. 119-100Open in workspace

§ 6712 Failure to disclose treaty-based return positions

(a) General rule

If a taxpayer fails to meet the requirements of section , 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.

(c) Penalty in addition to other penalties

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.)

Operative text only. Editorial notes, amendment history, and effective dates: official OLRC text of § 6712

Source: decipher.legal/usc/26/6712 · Internal Revenue Code, current through Pub. L. 119-100 (OLRC XML of 2026-04-17)