26 U.S.C. § 6712: Failure to disclose treaty-based return positions

(a) General ruleIf a taxpayer fails to meet the requirements of section 6114, there is hereby imposed a penalty equal to $1,000 ($10,000 in the case of a C corporation) on each such failure. (b) Authority to waiveThe Secretary may waive all or any part of the penalty provided by this section on a showing by the taxpayer that there was reasonable cause for the failure and that the taxpayer acted in good faith. (c) Penalty in addition to other penaltiesThe penalty imposed by this section shall be in addition to any other penalty imposed by law.