On September 24, 2010, the IRS issued the final Schedule UTP and instructions that require corporations to report so-called “uncertain tax positions,” or UTPs. In conjunction with finalizing the schedule, the IRS released Announcement 2010-75, explaining the changes it made to the final Schedule UTP from the draft schedule and instructions released April 29, 2010. Additionally, the IRS issued Announcement 2010-76, which details the IRS’s revisions to its policy of restraint with regard to seeking taxpayers’ tax accrual workpapers during audit, as well as an internal directive to the field which outlines the IRS’ plan for treating uncertain tax positions.
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