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26 U.S.C. § 6114 — Treaty-based return positions
Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** Each taxpayer who, with respect to any tax imposed by this title, takes the position that a treaty of the United States overrules (or otherwise modifies) an internal revenue law of the United States shall disclose (in such manner as the Secretary may prescribe) such position—
(1) on the return of tax for such tax (or any statement attached to such return), or
(2) if no return of tax is required to be filed, in such form as the Secretary may prescribe.
**(b) Waiver authority** The Secretary may waive the requirements of subsection (a) with respect to classes of cases for which the Secretary determines that the waiver will not impede the assessment and collection of tax.
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6114
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Stable record: federal_law:legal_authorities:record_usc_6fdf8f827ff687ba6a75957c
Source file: Laws/federal/codes/united-states-code/title-26/section-6114-treaty-based-return-positions--ee1b6689ca.md
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Source location: Title 26, Chapter 61, § 6114; chapter-061-information-and-returns.md
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**(a) In general** Each taxpayer who, with respect to any tax imposed by this title, takes the position that a treaty of the United States overrules (or otherwise modifies) an internal revenue law of the United States shall disclose (in such manner as the Secretary may prescribe) such position—
(1) on the return of tax for such tax (or any statement attached to such return), or
(2) if no return of tax is required to be filed, in such form as the Secretary may prescribe.
**(b) Waiver authority** The Secretary may waive the requirements of subsection (a) with respect to classes of cases for which the Secretary determines that the waiver will not impede the assessment and collection of tax.
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Federal law — U.S. Code and appendices · legal_authorities
**(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.
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6712
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Disclosure requirement** If an organization described in section 170(c) (other than paragraph (1) thereof) receives a quid pro quo contribution in excess of $75, the organization shall, in connection with the solicitation or receipt of the contribution, provide a written statement which—
(1) informs the donor that the amount of the contribution that is deductible for Federal income tax purposes is limited to the excess of the amount of any money and the value of any property other than money contributed by the donor over the value of the goods or services provided by the organization, and
(2) provides the donor with a good faith estimate of the value of such goods or services.
**(b) Quid pro quo contribution** For purposes of this section, the term “quid pro quo contribution” means a payment made partly as a contribution and partly in consideration for goods or services provided to the payor by the donee organization. A quid pro quo contribution does not include any payment made to an organization, organized exclusively for religious purposes, in return for which the taxpayer receives solely an intangible religious benefit that generally is not sold in a commercial transaction outside the donative context.
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6115
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Alternative minimum tax foreign tax credit** For purposes of this part—
(1) **In general** — The alternative minimum tax foreign tax credit for any taxable year shall be the credit which would be determined under section 27 for such taxable year if—
(A) the pre-credit tentative minimum tax were the tax against which such credit was taken for purposes of section 904 for the taxable year and all prior taxable years beginning after December 31, 1986,
(B) section 904 were applied on the basis of alternative minimum taxable income instead of taxable income, and
(C) the determination of whether any income is high-taxed income for purposes of section 904(d)(2) were made on the basis of the applicable rate specified in section 55(b)(1) in lieu of the highest rate of tax specified in section 1.
(2) **Pre-credit tentative minimum tax** — For purposes of this subsection, the term “pre-credit tentative minimum tax” means the amount determined under the first sentence of section 55(b)(1)(A).
(3) **Election to use simplified section 904 limitation**
(A) *In general* — In determining the alternative minimum tax foreign tax credit for any taxable year to which an election under this paragraph applies—
(i) subparagraph (B) of paragraph (1) shall not apply, and
(ii) the limitation of section 904 shall be based on the proportion which—
(I) the taxpayer’s taxable income (as determined for purposes of the regular tax) from sources without the United States (but not in excess of the taxpayer’s entire alternative minimum taxable income), bears to
(II) the taxpayer’s entire alternative minimum taxable income for the taxable year.
(B) *Election*
(i) *In general* — An election under this paragraph may be made only for the taxpayer’s first taxa
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 59
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Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** Each fundraising solicitation by (or on behalf of) an organization to which this section applies shall contain an express statement (in a conspicuous and easily recognizable format) that contributions or gifts to such organization are not deductible as charitable contributions for Federal income tax purposes.
**(b) Organizations to which section applies**
(1) **In general** — Except as otherwise provided in this subsection, this section shall apply to any organization which is not described in section 170(c) and which—
(A) is described in subsection (c) (other than paragraph (1) thereof) or (d) of section 501 and exempt from taxation under section 501(a),
(B) is a political organization (as defined in section 527(e)), or
(C) was an organization described in subparagraph (A) or (B) at any time during the 5-year period ending on the date of the fundraising solicitation or is a successor to an organization so described at any time during such 5-year period.
(2) **Exception for small organizations**
(A) *Annual gross receipts do not exceed $100,000* — This section shall not apply to any organization the gross receipts of which in each taxable year are normally not more than $100,000.
(B) *Multiple organization rule* — The Secretary may treat any group of 2 or more organizations as 1 organization for purposes of subparagraph (A) where necessary or appropriate to prevent the avoidance of this section through the use of multiple organizations.
(3) **Special rule for certain fraternal organizations** — For purposes of paragraph (1), an organization described in section 170(c)(4) shall be treated as described in section 170(c) only with respect to solicitations for contributions or gifts which are to be used exclusively for purposes referr
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6113
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Federal law — U.S. Code and appendices · legal_authorities
Page 3495
TITLE 26—INTERNAL REVENUE CODE
§ 6115
raising solicitation or is a successor to an
organization so described at any time during
such 5-year period.
(2) Exception for small organizations
(A) Annual gross receipts do not exceed
$100,000
This section shall not apply to any organi-
zation the gross receipts of which in each
taxable year are normally not more than
$100,000.
(B) Multiple organization rule
The Secretary may treat any group of 2 or
more organizations as 1 organization for pur-
poses of subparagraph (A) where necessary
or appropriate to prevent the avoidance of
this section through the use of multiple or-
ganizations.
(3) Special rule for certain fraternal organiza-
tions
For purposes of paragraph (1), an organiza-
tion described in section 170(c)(4) shall be
treated as described in section 170(c) only with
respect to solicitations for contributions or
gifts which are to be used exclusively for pur-
poses referred to in section 170(c)(4).
(c) Fundraising solicitation
For purposes of this section—
(1) In general
Except as provided in paragraph (2), the
term ‘‘fundraising solicitation’’ means any so-
licitation of contributions or gifts which is
made—
(A) in written or printed form,
(B) by television or radio, or
(C) by telephone.
(2) Exception for certain letters or calls
The term ‘‘fundraising solicitation’’ shall
not include any letter or telephone call if such
letter or call is not part of a coordinated fund-
raising campaign soliciting more than 10 per-
sons during the calendar year.
(Added Pub. L. 100–203, title X, § 10701(a), Dec. 22,
1987, 101 Stat. 1330–457.)
Editorial Notes
PRIOR PROVISIONS
A prior section 6113 was renumbered 6116 of this title.
Statutory Notes and Related Subsidiaries
EFFECTIVE DATE
Pub. L. 10
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6114
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