IRS releases guidance on Schedule UTP and policy of restraint

The IRS on March 23 released guidance in the form of answers to several frequently asked questions (FAQs) raised by taxpayers and practitioners with respect to reporting "uncertain tax positions" on the final Schedule UTP and earlier guidance, which the IRS had issued in September 2010. The new guidance addresses two primary areas: issues related to reporting on Schedule UTP and changes to the policy of restraint announced in Announcement 2010-76.