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 … More Musings in the Aftermath of the First Schedule UTP Filing Season
By Jonathan Prokup Peter Pappas at the Tax Lawyer’s Blog takes note of a recent report from TIGTA regarding audits of small corporations (those with less than $10 million in assets, according to the IRS). As Mr. Pappas says, language from the report suggests that Treasury may consider the closely held nature of many small … More Small Businesses, Schedule UTP, and High-Wealth Audits
By Phil Karter and Jonathan Prokup One of our readers recently emailed us with a question about the application of the new Schedule UTP to deferred tax assets. The question is straightforward enough: must uncertain positions involving deferred tax assets be reported on Schedule UTP and, if so, when must they be reported? The explanation, … More The Reporting Requirements for Deferred Tax Assets Under Schedule UTP: IRS Instructions Muddy The Waters
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 … More So It Begins: The Final Schedule UTP Is Out
Judging by the feedback we receive from our readers, the topic of workpapers and work product continues to be an area of major concern for many tax practitioners. For those who are interested in learning more about the topic, particularly in light of the D.C. Circuit’s recent decision in United States v. Deloitte LLP, I … More Speaking Alert: Work Product After Deloitte
By Jonathan Prokup and Dustin Covello Last week, the IRS issued a proposed regulation that would generally require corporations to attach Schedule UTP (Uncertain Tax Position Statement) to their returns. The regulation effectively would give the IRS authority to require that the schedule be filed; but the issuance of the regulation raises an interesting question: … More The Schedule UTP Regulation: Is The IRS Gearing Up For Battle?
By Jonathan Prokup Just when the Department of Justice must have thought that it could do no wrong in pursuing the workpapers of taxpayers and their auditors, it ran smack into the formidable blockade that is the Court of Appeals for the District of Columbia Circuit. In United States v. Deloitte LLP et al., No. … More The Workpaper Battle Continues: United States v. Deloitte LLP