The fee is imposed on “plans” not individuals (shareholders are not relevant at all) and the penalties set forth in U.S. Code § 6651 would apply if you don’t pay the fee.  Under 6651, there is a penalty equal to 5 percent of the unpaid PCORI fee for each month or part of a month that a return is late, but not greater than 25 percent of the unpaid PCORI fee. Penalties may not apply if the failure is due to reasonable cause and not due to willful neglect but reasonable cause is a tough standard to satisfy.