The IRS issued final regulations requiring some corporations to file a Schedule UTP, disclosing their uncertain tax positions when filing a return.
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Reporting & Filing Requirements
Deferral of Loss from Sale or Exchange Between Members
The IRS rejected a parent corporation’s argument that it was entitled to take into account a loss arising from its sale of domestic subsidiary (Sub1) stock to a foreign subsidiary (Sub2) as a result of the domestic subsidiary’s later liquidation.
IRS Set to Roll Out Uncertain Tax Positions Schedule
This column examines the concerns about the scope and direction of the IRS’s quest to roll out Schedule UTP, Uncertain Tax Position Statement, for tax year 2010.
IRS Releases Final Schedule UTP, Incorporates Changes
In two announcements, the IRS unveiled a number of significant changes to its plan to require certain business taxpayers to report uncertain tax positions on their tax returns and issued a final version of Schedule UTP.
IRS Issues Proposed Regs Requiring Disclosure of Uncertain Tax Positions
The IRS issued proposed regulations that would require certain business taxpayers to report uncertain tax positions on their tax returns.
Transparency and Compliance in Light of the New Schedule UTP
In April 2010, the IRS issued a draft of Schedule UTP, Uncertain Tax Position Statement, with Announcement 2010-30. This represents an important development in the longstanding and ongoing battle between taxpayers and the federal and state taxing authorities for access to tax accrual workpapers and other tax-related information.
IRS Taking Firm Approach to Ozone-Depleting Chemical Excise Tax Compliance
The IRS has recently reinvigorated its examination of the ozone-depleting chemicals tax, adopted a strict interpretation of the regulations, and instituted a laboratory testing program to detect ODCs in printed circuit boards.
IRS Releases Draft Schedule to Report Uncertain Tax Positions
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).
AICPA Submits Comments on IRS Uncertain Tax Position Proposal
The AICPA submitted comments to the IRS on the Service’s proposal to require certain business taxpayers to disclose their uncertain tax positions on their tax returns.
Are You Properly Paying the Ozone-Depleting Chemicals Excise Tax?
In recent years, IRS excise tax examinations have focused on taxpayers that import articles potentially subject to the excise tax imposed on certain ozone-depleting chemicals (ODCs) under Sec. 4681.
IRS to Require Uncertain Tax Position Reporting in 2010
The IRS followed up on its January 26 announcement about plans to require certain business taxpayers to report uncertain tax positions on their returns. It extended the ongoing comment period on the plan and announced that it will start requiring the reporting for tax years beginning in 2010 (Announcement 2010-17).
IRS Announces Release of Draft Schedule to Report Uncertain Tax Positions
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.
IRS Plans to Require Disclosure of UncertainTax Positions
The IRS said it is developing a schedule that certain businesses would be required to use to disclose uncertain tax positions on their returns annually.
Correcting Employment Tax Errors
Correcting an employment tax error that is discovered in the year in which the error occurs is generally a simple process. However, employers often discover such errors after the close of the calendar year in which they paid the wages to an employee. The adjustment process to correct those errors is confusing and often leads to further mistakes.
Legislation Extends Aviation Taxes
The Federal Aviation Administration Extension Act of 2009. This act extends the taxes that fund the Airport and Airway Trust Fund through the end of September.
Final Consolidated Return Regs. on Transactions Involving Intercompany Debt
The IRS issued final regulations for transactions involving debt obligations between members of a consolidated group.
IRS Intensifies Focus on Worker Classification
As the IRS intensifies its scrutiny of worker classification, businesses may want to take a fresh look at how their policies, procedures, and documentation around engaging independent contractors might withstand IRS review.
Court Reverses Broad-Based FICA Exclusion for Severance Payments
In March 2008, the Federal Circuit reversed a decision of the Court of Federal Claims that the qualification of payments as supplemental unemployment benefits under Sec. 3402 required the payments to be treated as nonwages for FICA tax purposes.
Final Regs. on Consolidated Group Liquidations
Final regulations effective January 15, 2008, explain how the members of a consolidated group succeed to tax items, or “attributes,” of a subsidiary corporation when two or more members of the group own stock in the subsidiary and the subsidiary is liquidated on a tax-free basis
FIN 48 Compliance: Disclosing Tax Positions in an Age of Uncertainty
FIN 48 presents new challenges for taxpayers, auditors, and tax advisers. The disclosures required by the interaction of FAS 109 and FIN 48 will result in greater public disclosure of tax planning techniques, including the strengths and weaknesses of those techniques.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
