Regs on Uncertain Tax Positions Clarified

The Internal Revenue Service blinked. The agency has retreated from some of the most worrisome and time-consuming provisions of its proposed requirement that companies report their uncertain tax positions with a new Form UTP. However, once the wording of the instructions for the new form is finalized, accountants and tax attorneys at companies with more than $100 million in assets will have to start preparing the new form, which will apply to the current tax year.

IRS Commissioner Douglas Shulman promised that his agency's long-standing "policy of restraint" would apply to the new measure, in terms of agency auditors using the new UTP form as a guide to which areas to audit.


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