November 1, 2011
MEMORANDUM FOR LB&I EMPLOYEES
FROM: Heather C. Maloy
Commissioner, Large Business & International Division
SUBJECT: UTP Guidance and Procedures for the Field
In May, I issued a memorandum outlining initial LB&I procedures for implementing the new Schedule UTP. Subsequently, on August 31, 2011, guidance was issued covering the use of Schedule UTP as part of the CAP Program that applied only to returns filed for the 2010 tax year by taxpayers that were in CAP in 2010. The purpose of this memorandum is to provide further Schedule UTP guidance and procedures applicable to all other LB&I examinations.
The attachment to this memorandum addresses the guidance you will follow for any examination that includes a return containing a Schedule UTP. In conjunction with this guidance, a Schedule UTP ELMS training module has been prepared, and will be available by December 31, 2011. Prior to starting the examination of any return that includes a Schedule UTP, employees and managers will be required to complete this mandatory ELMS training. The course information will be provided at the time a return with Schedule UTP is assigned to the field.
The enactment of the UTP reporting requirement was a significant milestone for the IRS. It is important that our implementation and use of the information is consistent with the expectations and framework set forth in this and other UTP notices and directives. I appreciate your support and assistance in helping LB&I achieve those objectives as we move forward in implementing UTP.
If you have any questions regarding this guidance, please send your questions in an email to the Schedule UTP Team. Additional information about UTP is also available on the LB&I intranet.