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

Small Businesses, Schedule UTP, and High-Wealth Audits

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 … Continue reading Small Businesses, Schedule UTP, and High-Wealth Audits

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

Speaking Alert: Work Product After Deloitte

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 … Continue reading Speaking Alert: Work Product After Deloitte

The Schedule UTP Regulation: Is The IRS Gearing Up For Battle?

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: … Continue reading The Schedule UTP Regulation: Is The IRS Gearing Up For Battle?

The Workpaper Battle Continues: United States v. Deloitte LLP

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. … Continue reading The Workpaper Battle Continues: United States v. Deloitte LLP