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

more+
less-

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.

Please see full article below for more information.

LOADING PDF: If there are any problems, click here to download the file.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morrison & Foerster LLP | Attorney Advertising

Written by:

more+
less-

Morrison & Foerster LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×
Loading...
×
×