26 USC 6707 - Failure to furnish information regarding reportable transactions

U.S Code last checked for updates: Feb 22, 2025

§ 6707.

Failure to furnish information regarding reportable transactions

(a)

In general

If a person who is required to file a return under section 6111(a) with respect to any reportable transaction—

(1)

fails to file such return on or before the date prescribed therefor, or

(2)

files false or incomplete information with the Secretary with respect to such transaction,

such person shall pay a penalty with respect to such return in the amount determined under subsection (b).

(b)

Amount of penalty

(1)

In general

(2)

Listed transactions

The penalty imposed under subsection (a) with respect to any listed transaction shall be an amount equal to the greater of—

(A)

$200,000, or

(B)

50 percent of the gross income derived by such person with respect to aid, assistance, or advice which is provided with respect to the listed transaction before the date the return is filed under section 6111.

Subparagraph (B) shall be applied by substituting “75 percent” for “50 percent” in the case of an intentional failure or act described in subsection (a).

(c)

Rescission authority

(d)

Reportable and listed transactions

(Added Pub. L. 98–369, div. A, title I, § 141(b), July 18, 1984, 98 Stat. 680; amended Pub. L. 99–514, title XV, §§ 1532(a), 1533(a), Oct. 22, 1986, 100 Stat. 2750; Pub. L. 105–34, title X, § 1028(b), (d), Aug. 5, 1997, 111 Stat. 927, 928; Pub. L. 108–357, title VIII, § 816(a), Oct. 22, 2004, 118 Stat. 1583.)

cite as: 26 USC 6707