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UTP Filing Statistics

Schedule UTP Filing Statistics (as of July 22, 2014)

Taxpayer Information: TY 2013

TY 2012

TY 2011

TY 2010

Sch. UTP filers 38

2,333

2,271

2,167

Percent of Repeat filers (filed Sch. UTP in multiple years) 87%

78%

77%

-

Percent of UTP filers that are Publicly Traded 58%

57%

61%

62%

   

 

 

 

Tax Position Information: TY 2013

TY 2012

TY 2011

TY 2010

Total Uncertain Tax Positions reported 151

5,807

5,841

5,202

% of Uncertain Tax Positions reported on Part II (Prior Year Positions) 39%

30%

21%

n/a

   

 

 

 

Average Uncertain Tax Position per Taxpayer 4.0

2.5

2.6

2.4

Percent of UTP Filers reporting only one Tax Position 55%

47%

46%

52%

   

 

 

 

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

 

  

  

  1) Research Credit - IRC 41 19%

24%

24%

21%

  2) Transfer Pricing - IRC 482 11%

22%

22%

22%

  3) Capitalization - IRC 263   (*) 3%

5%

6%

8%

  4) Taxes Foreign Countries - IRC 901 18%

2%

2%

2%

(*)  Based on FDRA analysis of UTP concise descriptions, IRC 263 "capitalization" was the 3rd most common tax position reported in tax years 2010, 2011, & 2012.  However, IRC sections reported by taxpayers on Sch. UTP indicate that IRC 162 "trade or business expenses" was the 3rd most common tax position.

 

Page Last Reviewed or Updated: 02-Oct-2014