# § 6726. Failure to comply with information reporting requirements relating to qualified opportunity funds and qualified rural opportunity funds
**(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.
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**Source Credit**: (Added Pub. L. 119–21, title VII, § 70421(d)(2)(A), July 4, 2025, 139 Stat. 230.)
## Statutory Notes and Related Subsidiaries
### Effective Date
Section applicable to taxable years beginning after , see , set out as an Effective Date of 2025 Amendment note under .