
From the U.S. Code Online via GPO Access
[wais.access.gpo.gov]
[Laws in effect as of January 2, 2001]
[Document not affected by Public Laws enacted between
  January 2, 2001 and January 28, 2002]
[CITE: 26USC6689]

 
                     TITLE 26--INTERNAL REVENUE CODE
 
                Subtitle F--Procedure and Administration
 
  CHAPTER 68--ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE 
                                PENALTIES
 
                   Subchapter B--Assessable Penalties
 
                       PART I--GENERAL PROVISIONS
 
Sec. 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) of section 905 or paragraph (2) of section 
404A(g).

(Added Pub. L. 96-603, Sec. 2(c)(2), Dec. 28, 1980, 94 Stat. 3509.)


                            Prior Provisions

    A prior section 6689, added Pub. L. 93-17, Sec. 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, 
Sec. 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) of Pub. L. 
96-603, set out as a note under section 404A of this title.
