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U.S.C.
Notes

§6048. Information with respect to certain foreign trusts — Inbound Citations

26 U.S.C. § 6048

Cited by 13 provisions in release 119-102.

Citations to 26 U.S.C. § 6048 as a whole

  • 26 U.S.C. § 679(a)(4)(A)
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    (A) If a nonresident alien individual has a residency starting date within 5 years after directly or indirectly transferring property to a foreign trust, this section and section 6048 shall be applied as if such individual transferred to such trust on the residency starting date an amount equal to the portion of such trust attributable to the property transferred by such individual to such trust in such transfer.
  • 26 U.S.C. § 679(a)(5)
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    (5) If—
    (A) an individual who is a citizen or resident of the United States transferred property to a trust which was not a foreign trust, and
    (B) such trust becomes a foreign trust while such individual is alive,
    then this section and section 6048 shall be applied as if such individual transferred to such trust on the date such trust becomes a foreign trust an amount equal to the portion of such trust attributable to the property previously transferred by such individual to such trust. A rule similar to the rule of paragraph (4)(B) shall apply for purposes of this paragraph.
  • 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. § 6662(j)(2)
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    (2) For purposes of this subsection, the term “undisclosed foreign financial asset” means, with respect to any taxable year, any asset with respect to which information was required to be provided under section 6038, 6038B, 6038D, 6046A, or 6048 for such taxable year but was not provided by the taxpayer as required under the provisions of those sections.
  • 26 U.S.C. § 6677(a)
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    (a) In addition to any criminal penalty provided by law, if any notice or return required to be filed by section 6048—
    (1) is not filed on or before the time provided in such section, or
    (2) does not include all the information required pursuant to such section or includes incorrect information,
    the person required to file such notice or return shall pay a penalty equal to the greater of $10,000 or 35 percent of the gross reportable amount. If any failure described in the preceding sentence continues for more than 90 days after the day on which the Secretary mails notice of such failure to the person required to pay such penalty, such person shall pay a penalty (in addition to the amount determined under the preceding sentence) of $10,000 for each 30-day period (or fraction thereof) during which such failure continues after the expiration of such 90-day period. At such time as the gross reportable amount with respect to any failure can be determined by the Secretary, any subsequent penalty imposed under this subsection with respect to such failure shall be reduced as necessary to assure that the aggregate amount of such penalties do not exceed the gross reportable amount (and to the extent that such aggregate amount already exceeds the gross reportable amount the Secretary shall refund such excess to the taxpayer).

Citations to §6048(a)

Citations to §6048(a)(3)(B)(ii)

Citations to §6048(b)

Citations to §6048(b)(1)

Citations to §6048(b)(1)(B)

Citations to §6048(c)