prohibited transaction
(2) Prohibited transactions For purposes of this subsection, the term “prohibited transaction” means any act or failure to act (other than with respect to section 4942(e) ) which would subject a foreign organization described in subsection (b), or a disqualified person (as defined in section 4946) with respect thereto, to liability for a penalty under section 6684 or a tax under section 507 if such foreign organization were a domestic organization.