§6046. Returns as to organization or reorganization of foreign corporations and as to acquisitions of their stock — Inbound Citations

Citations to 26 U.S.C. § 6046 as a whole

• 26 U.S.C. § 964(d)(1)

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  (1) For purposes of this chapter, section 6038, section 6046, and such other provisions as may be specified in regulations—

  (A) a qualified insurance branch of a controlled foreign corporation shall be treated as a separate foreign corporation created under the laws of the foreign country with respect to which such branch qualifies under paragraph (2), and

  (B) except as provided in regulations, any amount directly or indirectly transferred or credited from such branch to one or more other accounts of such controlled foreign corporation shall be treated as a dividend paid to such controlled foreign corporation.
• 26 U.S.C. § 6501(c)(8)(A)

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  (A) In the case of any information which is required to be reported to the Secretary pursuant to an election under section 1295(b) or under section 1298(f), 6038, 6038A, 6038B, 6038D, 6046, 6046A, or 6048, the time for assessment of any tax imposed by this title with respect to any tax return, event, or period to which such information relates shall not expire before the date which is 3 years after the date on which the Secretary is furnished the information required to be reported under such section.
• 26 U.S.C. § 6679(a)(1)

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  (1) In addition to any criminal penalty provided by law, any person required to file a return under section 6046 or 6046A who fails to file such return at the time provided in such section, or who files a return which does not show the information required pursuant to such section, shall pay a penalty of $10,000, unless it is shown that such failure is due to reasonable cause.