Updated UTP Guidance Clarifies Treatment of Net Operating Loss

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IRS offers more guidance to taxpayers on how they should report their uncertain tax positions to the government, addressing key questions surrounding the recording of a tax reserve and the treatment of net operating loss carryforwards, among other significant issues. The updated set of frequently asked questions and answers comes as the deadline approaches for the first wave of taxpayers to file the Schedule UTP, Statement of Uncertain Tax Position. The guidance adds eight new questions to the FAQ first unveiled in March and updates one existing question on whether interest and penalties should be included when taxpayers are “ranking” their positions on the new schedule.