Title 26 › Subtitle 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
People who must file the special information return for qualified opportunity funds must pay a penalty if they don’t file a complete and correct return on time. The normal penalty is $500 for each day the problem continues, but it cannot be more than $10,000 for one return. If the fund had more than $10,000,000 in assets at year end, the cap is $50,000. If the failure was done on purpose (intentional disregard), the daily penalty is $2,500, and the caps rise to $50,000 (general) and $250,000 (for funds over $10,000,000). For returns due in calendar years beginning after 2025, these dollar amounts will be increased for inflation using the cost-of-living rule in section 1(f)(3) with “calendar year 2024” substituted for “calendar year 2016.” After that increase, the daily amounts are rounded down to the next $10, the $10,000,000 asset threshold to the next $10,000, and other caps to the next $1,000.
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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 5, 2026
Release point: 119-73not60