Announcement 2010-9: A New IRS Approach to Transparency for Uncertain Tax Positions

IRS Announcement 2010-9 advances uncertain tax position reporting requirements under standards broader than Financial Accounting Standards Board Interpretation No. 48 (FIN 48) parameters. Affected taxpayers are concerned that the Schedule required with annual return filings could create a roadmap for...

Announcement 2010-9: A New IRS Approach to Transparency for Uncertain Tax Positions

IRS Announcement 2010-9 advances uncertain tax position reporting requirements under standards broader than Financial Accounting Standards Board Interpretation No. 48 (FIN 48) parameters. Affected taxpayers are concerned that the Schedule required with annual return filings could create a roadmap for...

Shulman's April 12th TEI Address Refines Announcement 2010-9 Message

IRS Commissioner Shulman addressed attendees at the Tax Executive Institute's 60th Mid-Year Meeting. In a concise presentation, he providied additional measured insight into the forces and envisioned methods driving the Service to establish new uncertain tax positions reporting standards. The...

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...

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...

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...

IRS Releases Final Schedule UTP and Instructions

By Robin L. Greenhouse , Joseph H. Selby , Kevin Spencer and Justin Jesse 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...

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...

Addressing and Sustaining Compliance with Uncertain Tax Position (UTP) Requirements

By Laura L. Roman Oil and gas companies face considerable uncertainties. Massive capital investment decisions hinge on projected international price trends. Shifting political climates in the United States and abroad affect the viability of business models. Even with the most sophisticated technology...

Addressing and Sustaining Compliance with Uncertain Tax Position (UTP) Requirements

By Laura L. Roman Oil and gas companies face considerable uncertainties. Massive capital investment decisions hinge on projected international price trends. Shifting political climates in the United States and abroad affect the viability of business models. Even with the most sophisticated technology...

IRS Issues Guidance for Schedule UTP Concise Descriptions

The IRS revised the Instructions for Schedule UTP in early February, but one thing that it did not change was the definition of the concise description required to accompany each uncertain tax position. The IRS later publicly expressed concerns over the small number of taxpayers (about 133) who offered...