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

• (a) If any person required to file a return under section 6039K fails to file a complete and correct return under such section in the time and in the manner prescribed therefor, such person shall pay a penalty of $500 for each day during which such failure continues.
• (b)
  • (1) The maximum penalty under this section on failures with respect to any 1 return shall not exceed $10,000.
  • (2) In the case of any failure described in subsection (a) with respect to a fund the gross assets of which (determined on the last day of the taxable year) are in excess of $10,000,000, paragraph (1) shall be applied by substituting “$50,000” for “$10,000”.
• (c) If a failure described in subsection (a) is due to intentional disregard, then—
  • (1) subsection (a) shall be applied by substituting “$2,500” for “$500”,
  • (2) subsection (b)(1) shall be applied by substituting “$50,000” for “$10,000”, and
  • (3) subsection (b)(2) shall be applied by substituting “$250,000” for “$50,000”.
• (d)
  • (1) 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), (b), and (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) for the calendar year determined by substituting “calendar year 2024” for “calendar year 2016” in subparagraph (A)(ii) thereof.
  • (2)
    • (A) If the $500 dollar amount in subsection (a) and (c)(1) or the $2,500 amount in subsection (c)(1), after being increased under paragraph (1), is not a multiple of $10, such dollar amount shall be rounded to the next lowest multiple of $10.
    • (B) If the $10,000,000 dollar amount in subsection (b)(2), after being increased under paragraph (1), is not a multiple of $10,000, such dollar amount shall be rounded to the next lowest multiple of $10,000.
    • (C) If any dollar amount in subsection (b) or (c) (other than any amount to which subparagraph (A) or (B) applies), after being increased under paragraph (1), is not a multiple of $1,000, such dollar amount shall be rounded to the next lowest multiple of $1,000.