§6712 — Title 26 Internal Revenue Code | U.S. Code

§6712 Failure to disclose treaty-based return positions

Title 26 › Subtitle Subtitle F— - Procedure and Administration › Chapter CHAPTER 68— - ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES › Subchapter Subchapter B— - Assessable Penalties › Part PART I— - GENERAL PROVISIONS › § 6712

Last updated Apr 6, 2026|Official source

Summary

If a taxpayer doesn't follow the rules in section 6114, they must pay a fine of $1,000 for each violation, or $10,000 for each violation by a C corporation. The government can cancel all or part of the fine if the taxpayer shows a good reason and acted in good faith, and the fine is extra to any other penalties.

Title 26, §6712

Internal Revenue Code — Source: USLM XML via OLRC

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

Notes & Related Subsidiaries

Editorial Notes

Codification Another section 6712 was renumbered section 6713 of this title.

Statutory Notes and Related Subsidiaries

Effective Date

Section applicable to taxable periods the due date for filing returns for which (without extension) occurs after Dec. 31, 1988, see section 1012(aa)(5)(D) of Pub. L. 100–647, set out as a note under section 6114 of this title.