26 U.S. Code § 6689 - Failure to file notice of redetermination of foreign tax

(a) Civil penalty
If the taxpayer fails to notify the Secretary (on or before the date prescribed by regulations for giving such notice) of a foreign tax redetermination, unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the deficiency attributable to such redetermination an amount (not in excess of 25 percent of the deficiency) determined as follows—
(1) 5 percent of the deficiency if the failure is for not more than 1 month, with
(2) an additional 5 percent of the deficiency for each month (or fraction thereof) during which the failure continues.
(b) Foreign tax redetermination defined
For purposes of this section, the term “foreign tax redetermination” means any redetermination for which a notice is required under subsection (c) ofsection 905 or paragraph (2) of section 404A (g).


(Added Pub. L. 96–603, § 2(c)(2),Dec. 28, 1980, 94 Stat. 3509.)
Prior Provisions

A prior section 6689, added Pub. L. 93–17, § 3(d)(2),Apr. 10, 1973, 87 Stat. 16, related to failure by certain foreign issuers and obligors to comply with United States investment equalization tax requirements, prior to repeal by Pub. L. 94–455, title XIX, § 1904(b)(10)(E)(i),Oct. 4, 1976, 90 Stat. 1817.
Effective Date

For applicability of section with respect to employer contributions or accruals for taxable years beginning after Dec. 31, 1979, election to apply amendments retroactively with respect to foreign subsidiaries, allowance of prior deductions in case of certain funded branch plans, and time and manner for making elections, see section 2(e) ofPub. L. 96–603, set out as a note under section 404A of this title.

The table below lists the classification updates, since Jan. 3, 2012, for this section. Updates to a broader range of sections may be found at the update page for containing chapter, title, etc.

The most recent Classification Table update that we have noticed was Tuesday, August 13, 2013

An empty table indicates that we see no relevant changes listed in the classification tables. If you suspect that our system may be missing something, please double-check with the Office of the Law Revision Counsel.

26 USCDescription of ChangeSession YearPublic LawStatutes at Large


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