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26 U.S.C. § 6707 — Failure to furnish information regarding reportable transactions

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 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** — Except as provided in paragraph (2), the penalty imposed under subsection (a) with respect to any failure shall be $50,000. (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** The provisions of section 6707A(d) (relating to authority of Commissioner to rescind penalty) shall apply to any penalty imposed under this section. **(d) Reportable and listed transactions** For purposes of this section, the terms “reportable transaction” and “listed transaction” have the respective meanings given to such terms by section 6707A(c).

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Source file: Laws/federal/codes/united-states-code/title-26/section-6707-failure-to-furnish-information-regarding-reportable-transactions--c3d10508a0.md
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Source location: Title 26, Chapter 68, § 6707; chapter-068-additions-to-the-tax-additional-amounts-and-assessable-penalties.md

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**(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** — Except as provided in paragraph (2), the penalty imposed under subsection (a) with respect to any failure shall be $50,000. (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** The provisions of section 6707A(d) (relating to authority of Commissioner to rescind penalty) shall apply to any penalty imposed under this section. **(d) Reportable and listed transactions** For purposes of this section, the terms “reportable transaction” and “listed transaction” have the respective meanings given to such terms by section 6707A(c).

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Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 6111 — Disclosure of reportable transactions

**(a) In general** Each material advisor with respect to any reportable transaction shall make a return (in such form as the Secretary may prescribe) setting forth— (1) information identifying and describing the transaction, (2) information describing any potential tax benefits expected to result from the transaction, and (3) such other information as the Secretary may prescribe. Such return shall be filed not later than the date specified by the Secretary. **(b) Definitions** For purposes of this section: (1) **Material advisor** (A) *In general* — The term “material advisor” means any person— (i) who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and (ii) who directly or indirectly derives gross income in excess of the threshold amount (or such other amount as may be prescribed by the Secretary) for such aid, assistance, or advice. (B) *Threshold amount* — For purposes of subparagraph (A), the threshold amount is— (i) $50,000 in the case of a reportable transaction substantially all of the tax benefits from which are provided to natural persons, and (ii) $250,000 in any other case. (2) **Reportable transaction** — The term “reportable transaction” has the meaning given to such term by section 6707A(c). **(c) Regulations** The Secretary may prescribe regulations which provide— (1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements, (2) exemptions from the requirements of this section, and (3) such rules as may be necessary or appropriate to carry out the purposes of this section.

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Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 6707 — Failure to furnish information regarding

Page 3809 TITLE 26—INTERNAL REVENUE CODE § 6707 § 6705. Failure by broker to provide notice to payors (a) In general Any person required under section 3406(d)(2)(B) to provide notice to any payor who willfully fails to provide such notice to such payor shall pay a penalty of $500 for each such failure. (b) Penalty in addition to other penalties Any penalty imposed by this section shall be in addition to any other penalty provided by law. (Added Pub. L. 98–67, title I, § 104(c)(1), Aug. 5, 1983, 97 Stat. 379.) Statutory Notes and Related Subsidiaries EFFECTIVE DATE Section effective with respect to payments made after Dec. 31, 1983, see section 110(a) of Pub. L. 98–67, set out as an Effective Date of 1983 Amendment note under section 31 of this title. § 6706. Original issue discount information re- quirements (a) Failure to show information on debt instru- ment In the case of a failure to set forth on a debt instrument the information required to be set forth on such instrument under section 1275(c)(1), unless it is shown that such failure is due to reasonable cause and not to willful ne- glect, the issuer shall pay a penalty of $50 for each instrument with respect to which such a failure exists. (b) Failure to furnish information to Secretary Any issuer who fails to furnish information re- quired under section 1275(c)(2) with respect to any issue of debt instruments on the date pre- scribed therefor (determined with regard to any extension of time for filing) shall pay a penalty equal to 1 percent of the aggregate issue price of such issue, unless it is shown that such failure is due to reasonable cause and not willful ne- glect. The amount of the penalty imposed under the preceding sentence with respect to any issue of debt instr

Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6707

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