opportunity funds and qualified rural opportunity funds (a) In general In the case of 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) Limitation (1) In general The maximum penalty under this section on failures with respect to any 1 return shall not exceed $10,000. (2) Large qualified opportunity funds 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) Penalty in cases of intentional disregard 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) Inflation adjustment (1) In general In the case of any failure relating to a return required to be filed in a calendar year beginning after 2023, each of the dollar amounts in subsections (a), (b), and (c) shall be increased by an amount equal to such dollar amount multiplied by the cost-of-living adjustment determined under section 1(f)(3) for the calendar year determined by substituting calendar year 2022 for calendar year 2016 in subparagraph (A)(ii) thereof. (2) Rounding (A) In general 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) Asset threshold 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