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

All Hands on Deck: The Case for Broadening the In-House Discussion of Tax Issues

By David L. Bernard TaxBlawg’s Guest Commentator, David L. Bernard, is the recently retired Vice President of Taxes for Kimberly-Clark Corporation, a past president of the Tax Executives Institute, and a periodic contributor to TaxBlawg. As the IRS sifts through dozens of comment letters on the proposed disclosure of uncertain tax positions, in-house tax officers … Continue reading All Hands on Deck: The Case for Broadening the In-House Discussion of Tax Issues

Trust but Verify – Proposed Schedule UTP and the Implications to Attorney Work Product

By Phil Karter Last week, at the TEI Midyear Conference in Washington, LMSB Commissioner Heather Maloy told corporate tax executives attending the conference that “trust” was the key to successfully implementing the new reporting requirements for uncertain tax positions first set forth in Announcement 2010-9.  As reported in the April 14th edition of Tax Notes, … Continue reading Trust but Verify – Proposed Schedule UTP and the Implications to Attorney Work Product

The Subliminal Message Underlying Announcement 2010-09

By Phil Karter Predictably, there has been a good deal of consternation accompanying the release of IRS Announcement 2010-09, which continues the trend away from the Service's traditional "policy of restraint" in seeking to uncover uncertain tax positions.  The first chink in this long-standing policy of restraint was exhibited in Announcement 2002-63, where the Service … Continue reading The Subliminal Message Underlying Announcement 2010-09