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UTP Filing Statistics

Schedule UTP TY2012 Filing Statistics (as of February 28, 2014)

Taxpayer Information:

TY 2012

TY 2011

TY 2010

Sch. UTP filers

1,940

2,190

2,143

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

77%

77%

-

Percent of UTP filers that are Publicly Traded

56%

56%

57%

 

 

 

 

Tax Position Information:

TY 2012

TY 2011

TY 2010

Total Uncertain Tax Positions reported

4,774

5,784

4,882

Uncertain Tax Positions reported on Part II (Prior Year Positions)

1,421

1,228

-

 

 

 

 

Average Uncertain Tax Position per Taxpayer

2.5

2.6

2.3

Percent of UTP Filers reporting only one Tax Position

49%

41%

47%

 

 

 

 

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

 

  

  

  1) Research Credit - IRC 41

23%

24%

22%

  2) Transfer Pricing - IRC 482

21%

23%

22%

  3) Capitalization - IRC 263   (*)

6%

6%

7%

 

 

 

 

(*)  Based on FDRA analysis of UTP concise descriptions, IRC 263 "capitalization" is the 3rd most common tax position reported.  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: 29-Apr-2014