26 USC § 6712 - Failure to disclose treaty-based return positions

---
identifier: "/us/usc/t26/s6712"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 6712 - Failure to disclose treaty-based return positions"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "6712"
section_name: "Failure to disclose treaty-based return positions"
chapter_number: 68
chapter_name: "ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES"
subchapter_number: "B"
subchapter_name: "Assessable Penalties"
part_number: "I"
part_name: "GENERAL PROVISIONS"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(Added Pub. L. 100–647, title I, § 1012(aa)(5)(B), Nov. 10, 1988, 102 Stat. 3532.)"
---


# § 6712. Failure to disclose treaty-based return positions

**(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.

**(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.

**(c)** **Penalty in addition to other penalties** The penalty imposed by this section shall be in addition to any other penalty imposed by law.

---

**Source Credit**: (Added Pub. L. 100–647, title I, § 1012(aa)(5)(B), Nov. 10, 1988, 102 Stat. 3532.)

## Editorial Notes

### Codification

Another section 6712 was renumbered .

## Statutory Notes and Related Subsidiaries

### Effective Date

Section applicable to taxable periods the due date for filing returns for which (without extension) occurs after , see , set out as a note under .