PRIA Logo™
Title 26, Internal Revenue CodeRelease 119-73

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

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

Last updated Apr 6, 2026|Official source

Summary

A fund that fails to file a complete and correct information return required of qualified opportunity funds owes a penalty of $500 for each day the failure continues. The total penalty per return is capped at $10,000, or $50,000 for funds with gross assets over $10,000,000. If the failure comes from intentional disregard, the daily penalty rises to $2,500 and the caps rise to $50,000 and $250,000. For returns due in calendar years after 2025, these dollar amounts are adjusted for inflation.

Full Legal Text

Title 26, §6726

Internal Revenue Code, Source: USLM XML via OLRC

(a)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)(1)The maximum penalty under this section on failures with respect to any 1 return shall not exceed $10,000.
(2)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)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)(1)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)(A)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)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)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

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

Apr 6, 2026

Release point: 119-73