---
kind: "section"
citation: "26 U.S.C. § 6726"
title: "26"
title_heading: "Internal Revenue Code"
number: "6726"
heading: "Failure to comply with information reporting requirements relating to qualified opportunity funds and qualified rural opportunity funds"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/6726"
units:
  - "Subtitle F — Procedure and Administration"
  - "Chapter 68 — Additions to the Tax, Additional Amounts, and Assessable Penalties"
  - "Subchapter B — Assessable Penalties"
  - "Part II — Failure to Comply with Certain Information Reporting Requirements"
---

# §6726. Failure to comply with information reporting requirements relating to qualified opportunity funds and qualified rural opportunity funds

- (a) **In general—** If any [person](/usc/26/7701.md?p=a-1) required to file a return under [section 6039K](/usc/26/6039K.md) fails to file a complete and correct return under such section in the time and in the manner prescribed therefor, such [person](/usc/26/7701.md?p=a-1) shall pay a penalty of $500 for each day during which such failure continues.
- (b) **Limitation—**
  - (1) **In general—** The maximum penalty under this section on failures with respect to any 1 return shall not exceed $10,000.
  - (2) **Large qualified opportunity funds—** In the case of any failure described in [subsection (a)](#a) with respect to a fund the gross assets of which (determined on the last day of the [taxable year](/usc/26/7701.md?p=a-23)) are in excess of $10,000,000, [paragraph (1)](#b-1) shall be applied by substituting “$50,000” for “$10,000”.
- (c) **Penalty in cases of intentional disregard—** If a failure described in [subsection (a)](#a) is due to intentional disregard, then—
  - (1) [subsection (a)](#a) shall be applied by substituting “$2,500” for “$500”,
  - (2) [subsection (b)(1)](#b-1) shall be applied by substituting “$50,000” for “$10,000”, and
  - (3) [subsection (b)(2)](#b-2) shall be applied by substituting “$250,000” for “$50,000”.
- (d) **Inflation adjustment—**
  - (1) **In general—** In the case of any failure relating to a return required to be filed in a calendar year beginning after 2025, each of the dollar amounts in subsections [(a)](#a), [(b)](#b), and [(c)](#c) shall be increased by an amount equal to—
    - (A) such dollar amount, multiplied by
    - (B) the cost-of-living adjustment determined under [section 1(f)(3)](/usc/26/1.md?p=f-3) for the calendar year determined by substituting “calendar year 2024” for “calendar year 2016” in subparagraph (A)(ii) thereof.
  - (2) **Rounding—**
    - (A) **In general—** If the $500 dollar amount in subsection [(a)](#a) and [(c)(1)](#c-1) or the $2,500 amount in [subsection (c)(1)](#c-1), after being increased under [paragraph (1)](#d-1), is not a multiple of $10, such dollar amount shall be rounded to the next lowest multiple of $10.
    - (B) **Asset threshold—** If the $10,000,000 dollar amount in [subsection (b)(2)](#b-2), after being increased under [paragraph (1)](#d-1), is not a multiple of $10,000, such dollar amount shall be rounded to the next lowest multiple of $10,000.
    - (C) **Other dollar amounts—** If any dollar amount in subsection [(b)](#b) or [(c)](#c) (other than any amount to which subparagraph [(A)](#d-2-A) or [(B)](#d-2-B) applies), after being increased under [paragraph (1)](#d-1), is not a multiple of $1,000, such dollar amount shall be rounded to the next lowest multiple of $1,000.

## Source credit

(Added Pub. L. 119–21, title VII, § 70421(d)(2)(A), July 4, 2025, 139 Stat. 230.)

## Notes

### Statutory Notes and Related Subsidiaries

### Effective Date

Section applicable to taxable years beginning after July 4, 2025, see section 70421(d)(5) of Pub. L. 119–21, set out as an Effective Date of 2025 Amendment note under section 6011 of this title.