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 II— - FAILURE TO COMPLY WITH CERTAIN INFORMATION REPORTING REQUIREMENTS › § 6726
If a person who must file the report under section 6039K does not file a complete and correct report on time and in the required way, they must pay $500 for each day the failure continues. The penalty for any one return normally cannot be more than $10,000. If the fund’s gross assets (measured on the last day of the tax year) are over $10,000,000, the cap for that return is $50,000. If the failure was intentional, the daily penalty becomes $2,500. The maximum per return becomes $50,000, and for funds with more than $10,000,000 in assets the cap is $250,000. For returns required in calendar years starting after 2025, these dollar amounts will be increased by a cost-of-living adjustment computed under section 1(f)(3) using “calendar year 2024” in place of “calendar year 2016.” After that increase, the daily amounts are rounded down to the nearest $10, the $10,000,000 asset threshold is rounded down to the nearest $10,000, and other adjusted dollar amounts are rounded down to the nearest $1,000.
Full Legal Text
Internal Revenue Code — Source: USLM XML via OLRC
Legislative History
Reference
Citation
26 U.S.C. § 6726
Title 26 — Internal Revenue Code
Last Updated
Apr 6, 2026
Release point: 119-73