26 U.S. Code § 6114 - Treaty-based return positions
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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—
Source(Added Pub. L. 100–647, title I, § 1012(aa)(5)(A),Nov. 10, 1988, 102 Stat. 3532; amended Pub. L. 101–508, title XI, § 11702(c),Nov. 5, 1990, 104 Stat. 1388–514.)
A prior section 6114 was renumbered 6116 of this title.
1990—Subsec. (b). Pub. L. 101–508struck out “by regulations” before “waive the requirements”.
Effective Date of 1990 Amendment
Amendment by Pub. L. 101–508effective as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 11702(j) ofPub. L. 101–508, set out as a note under section 59 of this title.
Pub. L. 100–647, title I, § 1012(aa)(5)(D),Nov. 10, 1988, 102 Stat. 3533, provided that: “The amendments made by this paragraph [enacting this section and section 6712 of this title and renumbering former section 6114 assection 6115 of this title] shall apply to taxable periods the due date for filing returns for which (without extension) occurs after December 31, 1988.”