IRS Releases Draft Schedule to Report Uncertain Tax Positions

By Alistair M. Nevius, J.D.

From the IRS

On April 19, the IRS announced that it was releasing draft Schedule UTP and draft instructions as part of its initiative to require certain business taxpayers to report uncertain tax positions on their returns (Announcement 2010-30).

According to the announcement, taxpayers with uncertain tax positions and assets of $10 million or more will be required to file Schedule UTP beginning with the 2010 tax year if they, or a related entity, filed audited financial statements. Affected taxpayers include corporations required to file Form 1120, insurance companies required to file Form 1120-L or 1120-PC, and foreign corporations required to file Form 1120-F.

For 2010 tax years, the IRS will not require Schedule UTP from taxpayers who file other forms in the 1120 series or from passthrough entities or tax-exempt organizations.

Under the draft instructions, a taxpayer who properly files Schedule UTP will be treated as having filed Form 8275, Disclosure Statement, or 8275-R, Regulation Disclosure Statement, and the IRS says it is considering other circumstances in which a taxpayer who reports a tax position on Schedule UTP need not report it elsewhere on the return or on another disclosure statement.

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