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Shahzad Malik on the recent IRS Announcement 2010-9 about uncertain tax position reporting.

On this edition, Shahzad A. Malik of Stradling, Yocca, Carlson & Rauth discusses recent IRS Announcement 2010-9 and its potential impact on corporate taxpayer reporting of uncertain tax positions. Mr. Malik analyzes the Announcement's effect on the "uncertain tax position" standard...

IRS Transparency Moves Portend Audit Encroachment

Attention to transparency enhancement aspirations enunciated in Announcement 2010-9 will be ncreasing as the June 1 deadline for comment approaches. Concerns are manifold, in spite of assurances being offered by Commissioner Shulman and others at the Service since the Announcement was released in January...

Proposed Schedule UTP Disclosure Requirements Striking a Nerve

Proposed uncertain tax position disclosure requirements, first enunciated in Announcement 2010-9 last January, are better defined now that the Service has rolled out Schedule UTP. Now potentially affected taxpayers are getting even more testy in challenging the integrity of the proposed reporting regime...

State Tax Issues Resulting from IRS Announcement 2010-9

The new IRS policy that requires taxpayers to disclose uncertain tax positions (UTPs) is getting some well-deserved attention. On April 19 the IRS issued a draft form Uncertain Tax Position Statement(Schedule UTP) for comment by June 1. Some tax professionals question the necessity or fundamental fairness...

What Will the States Do About Uncertain Tax Position Reporting?

There's no shortage of concerns being expressed by taxpayers and practitioners about uncertain tax position disclosure requirements. The Service has done its level best to clarify the vision for improved transparency ever since Announcement 2010-9 was issued in January. But try as it might, taxpayer...