26 U.S.C. § 6712 - U.S. Code - Unannotated Title 26. Internal Revenue Code § 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.