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