26 USC 6114 - Treaty-based return positions

U.S Code last checked for updates: May 16, 2024

§ 6114.

Treaty-based return positions

(a)

In general

Each taxpayer who, with respect to any tax imposed by this title, takes the position that a treaty of the United States overrules (or otherwise modifies) an internal revenue law of the United States shall disclose (in such manner as the Secretary may prescribe) such position—

(1)

on the return of tax for such tax (or any statement attached to such return), or

(2)

if no return of tax is required to be filed, in such form as the Secretary may prescribe.

(b)

Waiver authority

(Added Pub. L. 100–647, title I, § 1012(aa)(5)(A), Nov. 10, 1988, 102 Stat. 3532; amended Pub. L. 101–508, title XI, § 11702(c), Nov. 5, 1990, 104 Stat. 1388–514.)

cite as: 26 USC 6114