26 USC 6677 - Failure to file information with respect to certain foreign trusts

(a) Civil penalty 
In addition to any criminal penalty provided by law, if any notice or return required to be filed by section 6048
(1) is not filed on or before the time provided in such section, or
(2) does not include all the information required pursuant to such section or includes incorrect information,

the person required to file such notice or return shall pay a penalty equal to 35 percent of the gross reportable amount. If any failure described in the preceding sentence continues for more than 90 days after the day on which the Secretary mails notice of such failure to the person required to pay such penalty, such person shall pay a penalty (in addition to the amount determined under the preceding sentence) of $10,000 for each 30-day period (or fraction thereof) during which such failure continues after the expiration of such 90-day period. In no event shall the penalty under this subsection with respect to any failure exceed the gross reportable amount.

(b) Special rules for returns under section 6048 (b) 
In the case of a return required under section 6048 (b)
(1) the United States person referred to in such section shall be liable for the penalty imposed by subsection (a), and
(2) subsection (a) shall be applied by substituting 5 percent for 35 percent.
(c) Gross reportable amount 
For purposes of subsection (a), the term gross reportable amount means
(1) the gross value of the property involved in the event (determined as of the date of the event) in the case of a failure relating to section 6048 (a),
(2) the gross value of the portion of the trusts assets at the close of the year treated as owned by the United States person in the case of a failure relating to section 6048 (b)(1), and
(3) the gross amount of the distributions in the case of a failure relating to section 6048 (c).
(d) Reasonable cause exception 
No penalty shall be imposed by this section on any failure which is shown to be due to reasonable cause and not due to willful neglect. The fact that a foreign jurisdiction would impose a civil or criminal penalty on the taxpayer (or any other person) for disclosing the required information is not reasonable cause.
(e) Deficiency procedures not to apply 
Subchapter B of chapter 63 (relating to deficiency procedures for income, estate, gift, and certain excise taxes) shall not apply in respect of the assessment or collection of any penalty imposed by subsection (a).