(a) Civil penaltyIf the taxpayer fails to notify the Secretary (on or before the date prescribed by regulations for giving such notice) of a foreign tax redetermination, unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the deficiency attributable to such redetermination an amount (not in excess of 25 percent of the deficiency) determined as follows—(1) 5 percent of the deficiency if the failure is for not more than 1 month, with
(2) an additional 5 percent of the deficiency for each month (or fraction thereof) during which the failure continues.
(b) Foreign tax redetermination definedFor purposes of this section, the term “foreign tax redetermination” means any redetermination for which a notice is required under subsection (c) of section 905 or paragraph (2) of section 404A(g).
Structure US Code
Title 26— INTERNAL REVENUE CODE
Subtitle F— Procedure and Administration
CHAPTER 68— ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES
Subchapter B— Assessable Penalties
§ 6671. Rules for application of assessable penalties
§ 6672. Failure to collect and pay over tax, or attempt to evade or defeat tax
§ 6673. Sanctions and costs awarded by courts
§ 6674. Fraudulent statement or failure to furnish statement to employee
§ 6675. Excessive claims with respect to the use of certain fuels
§ 6676. Erroneous claim for refund or credit
§ 6677. Failure to file information with respect to certain foreign trusts
§ 6679. Failure to file returns, etc., with respect to foreign corporations or foreign partnerships
§ 6682. False information with respect to withholding
§ 6684. Assessable penalties with respect to liability for tax under chapter 42
§ 6686. Failure to file returns or supply information by DISC or former FSC
§ 6688. Assessable penalties with respect to information required to be furnished under section 7654
§ 6689. Failure to file notice of redetermination of foreign tax
§ 6690. Fraudulent statement or failure to furnish statement to plan participant
§ 6692. Failure to file actuarial report
§ 6694. Understatement of taxpayer’s liability by tax return preparer
§ 6695. Other assessable penalties with respect to the preparation of tax returns for other persons
§ 6695A. Substantial and gross valuation misstatements attributable to incorrect appraisals
§ 6696. Rules applicable with respect to sections 6694, 6695, and 6695A
§ 6698. Failure to file partnership return
§ 6699. Failure to file S corporation return
§ 6700. Promoting abusive tax shelters, etc.
§ 6701. Penalties for aiding and abetting understatement of tax liability
§ 6702. Frivolous tax submissions
§ 6703. Rules applicable to penalties under sections 6700, 6701, and 6702
§ 6704. Failure to keep records necessary to meet reporting requirements under section 6047(d)
§ 6705. Failure by broker to provide notice to payors
§ 6706. Original issue discount information requirements
§ 6707. Failure to furnish information regarding reportable transactions
§ 6707A. Penalty for failure to include reportable transaction information with return
§ 6708. Failure to maintain lists of advisees with respect to reportable transactions
§ 6709. Penalties with respect to mortgage credit certificates
§ 6710. Failure to disclose that contributions are nondeductible
§ 6712. Failure to disclose treaty-based return positions
§ 6713. Disclosure or use of information by preparers of returns
§ 6714. Failure to meet disclosure requirements applicable to quid pro quo contributions
§ 6715. Dyed fuel sold for use or used in taxable use, etc.
§ 6718. Failure to display tax registration on vessels
§ 6719. Failure to register or reregister
§ 6720. Fraudulent acknowledgments with respect to donations of motor vehicles, boats, and airplanes
§ 6720A. Penalty with respect to certain adulterated fuels