Musings in the Aftermath of the First Schedule UTP Filing Season

By Phil Karter As reported earlier this week in the tax press, the recently completed initial filing season for Schedule UTP produced at least one major surprise in the eyes of IRS officials, who had anticipated a much greater number of items listed on the average Schedule UTP than actually materialized.  In fact, the IRS’s … Continue reading Musings in the Aftermath of the First Schedule UTP Filing Season

Good News For Bank Account Disclosures By U.S. Citizens Residing In Canada

By Jonathan Prokup Over the weekend, a variety of Canadian news sources (see, e.g., the Financial Post and the Edmonton Journal) reported on anticipated guidance from the IRS, which would result in the waiver of penalties on certain U.S. citizens living in Canada for past failures to file Form TD F 90-22.1, commonly known as … Continue reading Good News For Bank Account Disclosures By U.S. Citizens Residing In Canada

Is Disclosure On Form 8275-R Required For A Position Contrary To A Revenue Ruling?

By Jonathan Prokup During a webinar the other week regarding the impact of the Mayo Foundation decision on taxpayers, I discussed the effect of Mayo on taxpayers’ decisions to take positions that are contrary to IRS rules or regulations.  Part of that discussion examined the 20-percent accuracy-related penalty that can be imposed on such positions … Continue reading Is Disclosure On Form 8275-R Required For A Position Contrary To A Revenue Ruling?

So It Begins: The Final Schedule UTP Is Out

By Jonathan Prokup The Internal Revenue Service on Friday released the final version of the much-anticipated Schedule UTP (and accompanying instructions) as well as additional guidance about changes that had been made the schedule.  At the same time, the IRS also announced an expansion of the Compliance Assurance Program (CAP) as well as some other … Continue reading So It Begins: The Final Schedule UTP Is Out