Schedule UTP: The IRS’s Most Aggressive Tax Position To Date


On September 24, 2010, the Internal Revenue Service released the anxiously anticipated final version of Schedule UTP (Uncertain Tax Positions) and associated instructions. The final version differed significantly from the original draft Schedule due in large part to extensive comments from the tax bar, the accounting profession and other interested parties. The proposed effective date of Schedule UTP is for tax years beginning after December 15, 2009 and ending after the date of publication of final regulations. See Prop. Reg. § 1.6012-2(a)(5).

The documents issued on September 24 are: *Announcement 2010-75, which explains the changes the IRS made to the proposed draft Schedule in reaching the final version; *Schedule UTP and Instructions; *Announcement 2010-76, which sets forth a modification to the policy of restraint regarding requests for tax accrual workpapers; *An IRS internal directive regarding policy of use of the UTP; and *Commissioner Shulman’s prepared remarks to the ABA Tax Section.

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