The IRS Adopts Largely Taxpayer-Favorable Changes To Schedule UTP

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In January 2010, the IRS announced that it would require corporate taxpayers with assets of over $10 million and audited financial statements to file a new Schedule UTP, disclosing information about their uncertain tax positions, with their 2010 tax returns. As originally proposed, Schedule UTP would have required a concise description of each uncertain tax position for which the taxpayer or a related entity had recorded a reserve in its financial statements, the reasons for determining that the position is an uncertain position, as well as the maximum amount of potential federal tax liability attributable to each uncertain tax position. The IRS also announced that it was studying potential penalties applicable to Schedule UTP.

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