Guidance on Uncertain Tax Positions Said to Offer Needed Clarity

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The government's new guidance on reporting uncertain tax positions offers eagerly awaited clarity in areas such as the treatment of net operating loss carryforwards and the circumstances under which a position would be considered certain enough not to require disclosure, Ernst & Young LLP practitioners say. Chester Abell, national director of tax accrual services, says IRS's recent set of frequently asked questions and answers provides guidance in a range of areas important to taxpayers. One important element, he says, is that taxpayers do not have to report the use of a net operating loss or credit carryover in a post-2009 return that reflects a pre-2010 uncertain position.