§6683. Failure of foreign corporation to file return of personal holding company tax

Any foreign corporation which-

(1) is a personal holding company for any taxable year, and

(2) fails to file or to cause to be filed with the Secretary a true and accurate return of the tax imposed by section 541,

shall, in addition to other penalties provided by law, pay a penalty equal to 10 percent of the taxes imposed by chapter 1 (including the tax imposed by section 541) on such foreign corporation for such taxable year. No penalty shall be imposed under this section on any failure which is shown to be due to reasonable cause and not willful neglect.

(Added Pub. L. 89–809, title I, §104(h)(4)(A), Nov. 13, 1966, 80 Stat. 1560 ; amended Pub. L. 94–455, title XIX, §1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834 ; Pub. L. 105–34, title XII, §1281(c), Aug. 5, 1997, 111 Stat. 1037 .)

Amendments

1997-Pub. L. 105–34 inserted at end "No penalty shall be imposed under this section on any failure which is shown to be due to reasonable cause and not willful neglect."

1976-Pub. L. 94–455 struck out "or his delegate" after "Secretary".

Effective Date of 1997 Amendment

Amendment by Pub. L. 105–34 applicable to taxable years beginning after Aug. 5, 1997, see section 1281(e) of Pub. L. 105–34, set out as a note under section 6652 of this title.

Effective Date

Section applicable with respect to taxable years beginning after Dec. 31, 1966, see section 104(n) of Pub. L. 89–809, set out as an Effective Date of 1966 Amendment note under section 11 of this title.