Press Room: Article

May 20, 2010

IRS Committed to Requiring Taxpayer Disclosure of Uncertain Tax Positions

On April 18, 2010, Internal Revenue Service (IRS) issued its long-awaited draft schedule for disclosure of uncertain tax positions, creatively named Schedule UTP, and a companion announcement, Announcement 2010-30. The form itself is accompanied by nine pages of instructions with numerous examples.

Notwithstanding push-back from the taxpayer and practitioner communities, IRS appears committed to pursuing this form of disclosure as a means to streamline and focus its resources. IRS indicates Schedule UTP will first be effective for returns filed for taxable years beginning in 2010. As a consequence, uncertain tax positions being taken in first quarter earnings releases may create disclosure obligations in the 2010 return.

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