(4) Failure to adopt rehabilitation plan (A) In general In the case of a multiemployer plan which is in critical status, there is hereby imposed a tax on the failure of such plan to adopt a rehabilitation plan within the time prescribed under section 432. (B) Amount of tax The amount of the tax imposed under subparagraph (A) with respect to any plan sponsor for any taxable year shall be the greater of— (i) the amount of tax imposed under subsection (a) for the taxable year (determined without regard to this subsection), or (ii) the amount equal to $1,100 multiplied by the number of days during the taxable year which are included in the period beginning on the day following the close of the 240-day period described in section 432(e)(1)(A) and ending on the day on which the rehabilitation plan is adopted. (C) Liability for tax (i) In general The tax imposed by subparagraph (A) shall be paid by each plan sponsor. (ii) Plan sponsor For purposes of clause (i), the term “plan sponsor” has the meaning given such term by section 432(j)(9).
26 USC § 4971(g)(4)
None identified, default scope is assumed to be the parent (chapter 43) of this section.