IRS Releases Draft Schedule and Instructions for Reporting Uncertain Tax Positions

Announcement 2010-30 provides additional details and clarifications regarding the type of information taxpayers will have to provide, but assumes that the IRS has the authority to require a taxpayer to provide information on uncertain tax positions. With Announcement 2010-30 (April 19, 2010...

The IRS Adopts Largely Taxpayer-Favorable Changes To Schedule UTP

By Mary E. Monahan , Thomas A. Cullinan, Joseph M. Depew, Sheldon M. Kay , Jerome B. Libin, Marc A. Simonetti , and Kendall C. Jones 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...

Schedule UTP Reporting and Proposed Treasury Regulations to Implement

By Ellen McElroy Ellen McElroy is a partner with Pepper Hamilton LLP, resident in the Washington D.C. office. She focuses on a broad variety of issues involving both accounting methods and inventories. Ms. McElroy has represented a number of clients in controversy matters, including IRS...

ALERT: Certainty for Reporting Uncertain Tax Positions (UTP) to IRS

By Seth Green , Christopher S. Rizek , Patricia Gimbel Lewis On September 24, the IRS issued a package of guidance finalizing the requirement that specified categories of corporate taxpayers include information as to "uncertain tax positions" as part of their tax return (Schedule UTP...

Schedule UTP: Leveling the Playing Field?

As the corporate tax filing season draws near, certain corporate taxpayers are required to report uncertain tax positions ("UTP") on their federal income tax returns. Public or privately held corporations that issue, or are included in, audited financial statements and that file a Form 1120...