Title 26, Internal Revenue CodeRelease 119-110

§6726 Failure to Comply with Information Reporting Requirements Relating to Qualified Opportunity Funds and Qualified Rural Opportunity Funds

Title 26 › Subtitle F — Procedure and Administration › CHAPTER 68 — ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES › Subchapter B — Assessable Penalties › PART II — FAILURE TO COMPLY WITH CERTAIN INFORMATION REPORTING REQUIREMENTS › § 6726

Last updated Sep 22, 2026|Official source

Summary

People who must file the form under section 6039K must pay $500 for each day they do not file a complete and correct return. The penalty for one return cannot be more than $10,000. If the fund’s gross assets on the last day of the tax year are more than $10,000,000, that cap is $50,000. If the failure is intentional, the daily penalty is $2,500, and the caps are $50,000 (usual) and $250,000 (large funds). For returns required in calendar years that begin after 2025, all dollar amounts are raised by the cost-of-living adjustment under section 1(f)(3) using calendar year 2024 instead of 2016. After that increase, the $500 and $2,500 amounts round down to the next $10, the $10,000,000 asset threshold rounds down to the next $10,000, and other dollar amounts in the caps round down to the next $1,000.

Full Legal Text

Title 26, §6726

Internal Revenue Code, Source: USLM XML via OLRC

(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.
(b)Limitation
(1)In general
The maximum penalty under this section on failures with respect to any 1 return shall not exceed $10,000.
(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”.
(c)Penalty in cases of intentional disregard
If a failure described in subsection (a) is due to intentional disregard, then—
(1)subsection (a) shall be applied by substituting “$2,500” for “$500”,
(2)subsection (b)(1) shall be applied by substituting “$50,000” for “$10,000”, and
(3)subsection (b)(2) shall be applied by substituting “$250,000” for “$50,000”.
(d)Inflation adjustment
(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—
(A)such dollar amount, multiplied by
(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.
(2)Rounding
(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.
(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.
(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.

Legislative History

Notes & Related Subsidiaries

Inflation Adjusted Items for Certain YearsFor inflation adjustment of certain items in this section, see Revenue Procedures listed in a table under section 1 of this title.

Statutory Notes and Related Subsidiaries

Effective Date

Section applicable to taxable years beginning after July 4, 2025, see section 70421(d)(5) of Pub. L. 119–21, set out as an

Effective Date

of 2025 Amendment note under section 6011 of this title.

Reference

Citations & Metadata

Citation

26 U.S.C. § 6726

Title 26, Internal Revenue Code

Last Updated

Sep 22, 2026

Release point: 119-110