Tangible Property Rules Could Create Uncertain Tax Positions, E&Y Says

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Taxpayers seeking to comply with new IRS regulations (T.D. 9564, REG-168745-03) on the accounting treatment of tangible property may have issues arising in the uncertain tax positions area for the first quarter of 2012, say Ernst & Young LLP practitioners. The regulations may act as a triggering event for creating an uncertain tax position that has to be reported to IRS, according to Angela Evans, practitioner with E&Y's Tax Accounting and Risk Advisory Services. The development comes as taxpayers work to comply with the comprehensive new rules, which are effective for 2012, while at the same time many are determining whether they have UTPs that need to be disclosed.