In a move likely to meet with resistance from corporations, theInternal Revenue Service has proposed new rules that would requirecompanies to provide the agency with a list of their “uncertain taxpositions.”

The IRS's proposal “will certainly change the dynamic in manyaudits,” says Matt Miller, senior director for tax and economicpolicy at Financial Executives International (FEI.) “Just the merefact of identifying issues as uncertain is significant and reallykind of provides a road map to the IRS, which obviously is ofconcern to companies.”

FEI supports transparency, Miller says, but the IRS proposal“appears to go beyond transparency. It involves the disclosure ofexposure items to possible adversaries.”