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Summary of AJCA ’04 Provisions

American Jobs Creation Act of 2004 (AJCA'04) amended IRC § 4101(d) to mandate electronic reporting of Forms 720 TO / CS if there are 25 or more transactions in a month. Penalties were strengthened by AJCA as follows:

  • IRC § 6719 -failure to register with IRS on Form 637
    • $10,000 for each failure to register, and
    • $1,000 a day for each day the failure continues.
  • IRC § 6725  - $10,000 for each report

    • Failure to file on or before the due date;
    • Failure to include all of the required information; or
    • Inclusion of incorrect information

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Page Last Reviewed or Updated: 13-Sep-2016