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In a move likely to meet with resistance from corporations, the Internal Revenue Service has proposed new rules that would require companies to provide the agency with a list of their “uncertain tax positions.”

The IRS’s proposal “will certainly change the dynamic in many audits,” says Matt Miller, senior director for tax and economic policy at Financial Executives International (FEI.) “Just the mere fact of identifying issues as uncertain is significant and really kind of provides a road map to the IRS, which obviously is of concern to companies.”

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