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UTP Filing Statistics

Schedule UTP Filing Statistics (as of April 20,  2015)

Taxpayer Information: TY 2013

TY 2012

TY 2011

TY 2010

Sch. UTP filers 2,090

2,399

2,271

2,167

Percent of Repeat filers (filed Sch. UTP in multiple years) 80%

77%

77%

-

Percent of UTP filers that are Publicly Traded 57%

58%

61%

62%

Percent of UTP Filers reporting only one Tax Position 46%

47%

47%

53%

         
Tax Position Information: TY 2013

TY 2012

TY 2011

TY 2010

Total Uncertain Tax Positions reported 5,110

5,754

5,367

4,742

% of Uncertain Tax Positions reported on Part II (Prior Year Positions) 33%

30%

21%

n/a

Average Uncertain Tax Position per Taxpayer 2.5

2.4

2.4

2.2

         
Most commonly reported Uncertain Tax Positions (% of total):  

 

  

  

  1) Research Credit - IRC 41 32%

25%

24%

21%

  2) Transfer Pricing - IRC 482 18%

22%

22%

22%

  3) Capitalization - IRC 263   (*) 4%

5%

6%

7%

  4) Domestic Prod. Activities - IRC 199 5%

5%

4%

4%

(*)  Based on FDRA analysis of UTP concise descriptions, IRC 263 – Capitalization was determined to be the 3rd most common tax position reported. However, taxpayers reported IRC 162 - Trade or Business Expenses as the 3rd most common tax position.

 

Page Last Reviewed or Updated: 30-Jul-2015