In February, the IRS announced its intent to require certain corporate taxpayers to report “uncertain tax positions” (“UTP”) as part of their income tax returns beginning with the 2010 tax year.1 In April, the IRS released for public comment its draft of Schedule UTP and the related instructions for completing the form.2 The comment period ended on June 1, 2010, and the final form and instructions could be issued at any time.

Generally, reporting will be required beginning with the 2010 tax year.