26 U.S. Code § 6712 - Failure to disclose treaty-based return positions
(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.
Source(Added Pub. L. 100–647, title I, § 1012(aa)(5)(B),Nov. 10, 1988, 102 Stat. 3532.)