LB&I memo provides insights into IRS thinking on use of Schedule UTP during exams

Washington National Tax Services
A memorandum issued August 31 by Heather Maloy, Commissioner of the IRS's Large Business & International Division (LB&I), to LB&I examination teams assigned to the Compliance Assurance Process (CAP) Program addresses CAP Program examiners' use of Schedule UTP, Uncertain Tax Position Statement. The guidance is significant in that it provides the first specific indication of how the IRS will use the Schedule UTP during the course of an examination. The August 31 memorandum supplements a May 11 memorandum that provides general guidance on LB&I's centralized management of Schedules UTP filed with taxpayers' income tax returns.

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