Table of Contents

• Announcement 2010-75
  • Overview of major changes to the draft schedule and instructions
    • Five-year phase-in period
    • No reporting of maximum tax adjustment
    • Removal of requirement to include rationale and nature of uncertainty in concise description of the position
    • No reporting of administrative practice tax positions
    • Consistency between Schedule UTP reporting and financial statement reserve decisions
    • Additional areas of clarification
    • Privilege, work product doctrine, subject matter waiver, and policy of restraint comments
  • Other comments — exclude certain tax positions and expectation to litigate
  • Internal Directive and related changes
    • Exchange of information with foreign governments
    • Future guidance and changes
    • Penalties
    • Coordination with Forms 8275 and 8886
• Announcement 2010-76
  • BACKGROUND
  • POLICY OF RESTRAINT
  • DRAFTING INFORMATION
• Announcement 2010-77
  • FOR FURTHER INFORMATION CONTACT:
• Announcement 2010-78