Uncertain Tax Positions

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Uncertain Tax Positions - Schedule UTP

Uncertain Tax Position Reporting to Start with 2010 Tax Years

The IRS has finalized Schedule UTP and instructions that certain corporations will use starting with 2010 tax years to report uncertain tax positions. Additionally, with Announcement 2010-76, IRS is expanding its policy of restraint in connection with its decision to require certain corporations to file Schedule UTP. A directive to LMSB personnel has also been issued setting forth the IRS’s planned treatment of these UTPs by examiners and other personnel.

Related Documents:

UTP Guidance and Procedures for the Field

UTP Guidance and Procedures for the Compliance Assurance Process (CAP) Program

Centralized Management of LB&I Returns with UTP Schedules

Uncertain Tax Positions - Modified Policy of Restraint

Announcement 2010-75, Reporting of Uncertain Tax Positions

Form 1120 Schedule UTP

Frequently Asked Questions, Revised 07/19/2011

Instructions for Form 1120 Schedule UTP

Directive for LMSB: Reporting of Uncertain Tax Positions

Announcement 2010-76, Policy of Restraint and Uncertain Tax Positions

IRS Commissioner Shulman Remarks before the American Bar Association, 9/24/2010