Fabio
76b8ec33a7
Ingested titles 12–51 and 54 from OLRC USLM XML @119-100 (the whole Code now, uniform edition; Title 53 is reserved/empty). LegalText 11,221 -> 59,740; repo total 105,704 records. Deterministic (byte-identical rerun, verified on Title 42's 8,356 sections); make check green. make legal-us-code default now covers every title. Co-Authored-By: Claude Opus 4.8 <noreply@anthropic.com>
50 lines
2.1 KiB
Markdown
50 lines
2.1 KiB
Markdown
---
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type: "LegalText"
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title: "26 U.S.C. § 6712"
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description: "Failure to disclose treaty-based return positions"
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jurisdiction: "us"
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corpus: "united_states_code"
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kind: "code_section"
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title_number: 26
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title_name: "INTERNAL REVENUE CODE"
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chapter_number: "68"
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chapter_name: "ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES"
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section: "6712"
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citation: "26 U.S.C. § 6712"
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status: "current"
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release_point: "119-100"
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release_date: "2026-06-26"
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source: "official"
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source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
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source_identifier: "/us/usc/t26/s6712"
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source_file: "data/legal/raw/us/code/title-26/usc26.xml"
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source_hash: "3b8cfccc88dc08c7cb6f888c44d3dcac3d2d575a0036301e219986b080e70b5b"
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raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
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text_hash: "03fdd8dbfbbb8fc2fd3b2b4ab5d28e375520f80ae996f6f95671b48427c8db7a"
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retrieved_at: "2026-07-04"
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confidence: "official"
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tags: ["legal", "us-code"]
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---
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# 26 U.S.C. § 6712 - Failure to disclose treaty-based return positions
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## Text
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(a) General rule 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.
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(b) Authority to waive 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.
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(c) Penalty in addition to other penalties The penalty imposed by this section shall be in addition to any other penalty imposed by law.
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(Added Pub. L. 100–647, title I, § 1012(aa)(5)(B), Nov. 10, 1988, 102 Stat. 3532.)
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## Notes
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Editorial Notes
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Codification Another section 6712 was renumbered section 6713 of this title.
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Statutory Notes and Related Subsidiaries
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Effective DateSection 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.
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