Undisclosed tax positions

Rev. Proc. Updates Guidance on Adequate Disclosure of Return Positions

The IRS released its annual update identifying when a taxpayer’s disclosure of an item or position in an income tax return is adequate for purposes of reducing the understatement of tax penalty and the tax return preparer penalty for understatement due to unreasonable positions.

Schedule UTP: IRS Findings

Recent data show what the IRS has found regarding Schedule UTP filings by corporations with $100 million or more of total assets on their tax return balance sheets, and what the IRS is doing with that information. 

Annual Update on Adequate Disclosure of Return Positions Issued

The IRS released updated guidance identifying when a taxpayer’s disclosure of an item or position in an income tax return is adequate for purposes of reducing the understatement of tax penalty and the tax return preparer penalty for understatement due to unreasonable positions.

Schedule UTP: IRS Mandates Disclosure of Uncertain Tax Positions

This article explores the requirements of Schedule UTP, discusses modifications to the IRS’s policy of restraint pertaining to tax reconciliation workpapers, and suggests how to avoid the inadvertent waiver of the work-product privilege for documents relating to uncertain tax positions.

Reporting Uncertain Tax Positions

This item explores the differences between financial statement reporting and federal income tax return disclosure in preparing for disclosure of uncertain tax positions on the Schedule UTP,

Uncertain Tax Position FAQs Posted

The IRS has posted a series of questions and answers (FAQs) about the new requirement for large corporations to report their uncertain tax positions.

IRS Introduces Final Schedule UTP with Modifications

The issuance of a final schedule and instructions makes it important for companies with assets of $100 million or more that issue audited financial statements to prepare for filing the Schedule UTP with their 2010 tax returns.

IRS Updates Guidance on Adequate Disclosure of Positions

The IRS has released updated guidance identifying when a taxpayer’s disclosure of an item or position in an income tax return is adequate for purposes of reducing the understatement of tax penalty and the tax return preparer penalty for understatement due to unreasonable positions.

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.

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.

Newsletter Articles

TAX REFORM

Traps for the unwary: Tax Cuts and Jobs Act changes

By now many of us are familiar with the various provisions of the law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. Here is a list of changes together with (perhaps) unexpected nuances.

DEDUCTIONS

Qualified business income deduction regs. and other guidance issued

The package includes final regulations, guidance on how to calculate W-2 wages, a safe-harbor rule for rental real estate businesses, and new proposed rules on the treatment of previously suspended losses.