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26 U.S.C. § 6046A — Returns as to interests in foreign partnerships
Federal law — U.S. Code and appendices · legal_authorities
**(a) Requirement of return** Any United States person, except to the extent otherwise provided by regulations—
(1) who acquires any interest in a foreign partnership,
(2) who disposes of any portion of his interest in a foreign partnership, or
(3) whose proportional interest in a foreign partnership changes substantially,
shall file a return. Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.
**(b) Form and contents of return** Any return required by subsection (a) shall be in such form and set forth such information as the Secretary shall by regulations prescribe.
**(c) Time for filing return** Any return required by subsection (a) shall be filed on or before the 90th day (or on or before such later day as the Secretary may by regulations prescribe) after the day on which the United States person becomes liable to file such return.
**(d) 10-percent interest** For purposes of subsection (a), a 10-percent interest in a partnership is an interest described in section 6038(e)(3)(C).
**(e) Cross reference** For provisions relating to penalties for violations of this section, see sections 6679 and 7203.
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Source location: Title 26, Chapter 61, § 6046A; chapter-061-information-and-returns.md
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**(a) Requirement of return** Any United States person, except to the extent otherwise provided by regulations—
(1) who acquires any interest in a foreign partnership,
(2) who disposes of any portion of his interest in a foreign partnership, or
(3) whose proportional interest in a foreign partnership changes substantially,
shall file a return. Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.
**(b) Form and contents of return** Any return required by subsection (a) shall be in such form and set forth such information as the Secretary shall by regulations prescribe.
**(c) Time for filing return** Any return required by subsection (a) shall be filed on or before the 90th day (or on or before such later day as the Secretary may by regulations prescribe) after the day on which the United States person becomes liable to file such return.
**(d) 10-percent interest** For purposes of subsection (a), a 10-percent interest in a partnership is an interest described in section 6038(e)(3)(C).
**(e) Cross reference** For provisions relating to penalties for violations of this section, see sections 6679 and 7203.
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Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** The Secretary shall mail to the partnership and the partnership representative—
(1) notice of any administrative proceeding initiated at the partnership level with respect to an adjustment of any partnership-related item for any partnership taxable year, or any partner’s distributive share thereof,
(2) notice of any proposed partnership adjustment resulting from such proceeding, and
(3) notice of any final partnership adjustment resulting from such proceeding.
Any notice of a final partnership adjustment shall be sufficient if mailed to the last known address of the partnership representative or the partnership (even if the partnership has terminated its existence). The first sentence shall apply to any proceeding with respect to an administrative adjustment request filed by a partnership under section 6227.
**(b) Timing of notices**
(1) **Notice of proposed partnership adjustment** — Any notice of a proposed partnership adjustment shall not be mailed later than the date determined under section 6235 (determined without regard to paragraphs (2) and (3) of subsection (a) thereof).
(2) **Notice of final partnership adjustment**
(A) *In general* — Except to the extent that the partnership elects to waive the application of this subparagraph, any notice of a final partnership adjustment shall not be mailed earlier than 270 days after the date on which the notice of the proposed partnership adjustment is mailed.
(B) *Statute of limitations on adjustment* — For the period of limitations on making adjustments, see section 6235.
**(c) Further notices restricted** If the Secretary mails a notice of a final partnership adjustment to any partnership for any partnership taxable year and the partnership files a petition under section 6234 with respect
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6231
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Civil penalty**
(1) **In general** — In addition to any criminal penalty provided by law, any person required to file a return under section 6046 or 6046A who fails to file such return at the time provided in such section, or who files a return which does not show the information required pursuant to such section, shall pay a penalty of $10,000, unless it is shown that such failure is due to reasonable cause.
(2) **Increase in penalty where failure continues after notification** — If any failure described in paragraph (1) continues for more than 90 days after the day on which the Secretary mails notice of such failure to the United States person, such person shall pay a penalty (in addition to the amount required under paragraph (1)) of $10,000 for each 30-day period (or fraction thereof) during which such failure continues after the expiration of such 90-day period. The increase in any penalty under this paragraph shall not exceed $50,000.
**(b) Deficiency procedures not to apply** Subchapter B of chapter 63 (relating to deficiency procedure for income, estate, gift, and certain excise taxes) shall not apply in respect of the assessment or collection of any penalty imposed by subsection (a).
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6679
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Federal law — U.S. Code and appendices · legal_authorities
Page 3368
TITLE 26—INTERNAL REVENUE CODE
§ 6046A
Subsec. (c). Pub. L. 87–834 substituted provisions re-
quiring, for purposes of subsec. (a), stock owned di-
rectly or indirectly by a person (including, in the case
of an individual, stock owned by members of his fam-
ily) to be taken into account for provisions which de-
fined ‘‘United States shareholder’’.
Subsecs. (d) to (f). Pub. L. 87–834 added subsecs. (d)
and (e) and redesignated former subsec. (d) as (f) and in-
serted a reference to section 6679 of this title.
1960—Pub. L. 86–780 substituted ‘‘Returns as to cre-
ation or organization, or reorganization, of foreign cor-
porations’’ for ‘‘Returns as to formation or reorganiza-
tion of foreign corporations’’ in section catchline.
Subsec. (a). Pub. L. 86–780 substituted requirement
that returns relating to the creation, organization, or
reorganization of foreign corporations be made by
every citizen or resident of the United States who was
an officer or director of the corporation at any time
within 60 days after its creation, organization, or reor-
ganization, and by every United States shareholder of
the corporation owning at least 5 percent of its out-
standing stock at any time within such 60 days for re-
quirement that every attorney, accountant, fiduciary,
bank, trust company, financial institution, or other
person, who advises as to the formation or reorganiza-
tion of a foreign corporation, file a return in accord-
ance with regulations prescribed by the Secretary of
the Treasury or his delegate.
Subsec. (b). Pub. L. 86–780 reenacted the substance of
subsec. (b), struck out ‘‘to the full extent of the infor-
mation within the possession or knowledge or under
the control of the person required to make the return’’
before ‘‘such information’
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6046A
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