IRS updates Schedule UTP FAQs

July 2011


The IRS on July 19 released responses to some frequently asked questions (FAQs) that have been raised by taxpayers and practitioners with respect to the final Schedule UTP. The release supplements the March 23, 2011, FAQs and addresses four primary issues with respect to Schedule UTP reporting. The general disclosure requirements of Schedule UTP as originally released by the IRS remain unchanged. A corporate taxpayer meeting all other filing requirements is required to disclose tax positions on Schedule UTP if the following two conditions are met: (1) the corporation has taken a tax position on its U.S. federal income tax return for the current or for a prior tax year and (2) either the corporation, or a related party, has recorded a reserve with respect to that position for U.S. federal income tax in audited financial statements or did not record a reserve for the position because the corporation expects to litigate the position. The new guidance clarifies and explains many taxpayers' concerns and comments.

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