§ 28.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.

26 C.F.R. Part 28 — Imposition Of Tax On Gifts And Bequests From Covered Expatriates · 2026 edition · updated 2026-10-04 · United States

(a) In general. A person who is a tax return preparer of any return or claim for refund of any section 2801 tax is subject to penalties under section 6694(b) of the Code in the manner stated in § 1.6694-3 of this chapter.

(b) Applicability date. This section applies to returns and claims for refund filed, and advice provided, on or after January 14, 2025.

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▸Contents — 26 C.F.R. Part 28 — Imposition Of Tax On Gifts And Bequests From Covered Expatriates

26 C.F.R. Part 28 — Imposition Of Tax On Gifts And Bequests From Covered Expatriates

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