TaxGuided
United States IRC sections

Statute section

IRC section 6114

Treaty-based return positions

Country

United States

Section

6114

Updated

2026-05-04

Operative text

Section 6114 requires disclosure when a taxpayer takes the position that a U.S. treaty overrules or otherwise modifies an internal revenue law of the United States. In practical terms, this is the Code hook behind Form 8833 and many treaty-disclosure questions faced by cross-border taxpayers.

Cross-references

26 U.S.C. 671226 U.S.C. 7701

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Primary sources

Important disclaimer

This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.