The New Rules for Uncertain Tax Positions: A Chance for the IRS to Dig Into Your Past?
Many corporate taxpayers face a new compliance task this year — filing the new Schedule UTP with their tax returns for 2010. And many of them are jittery about it, as I noted here. One concern is that IRS might use the disclosures to throw light on uncertain tax positions taken in years before 2010 that might still be under audit.
I asked Stephen O’Connell, partner, and Jeff Malo, director with business and tax advisory firm WTP Advisors, for their take on this issue. They supplied detailed responses in this email exchange:
John Cummings: I suspect that many tax and finance folks may have missed the fact that the new UTP requirement has implications for past-year returns. Is that your impression too?
WTP Advisors: Many people have overlooked the implications that Schedule UTP has for uncertain tax positions established prior to 2010. The 2010 compliance season marks the first time that corporate taxpayers with net assets equal to or exceeding $100 million are required to file Schedule UTP with their annual corporate income tax return. more








