IRS Guidance to Focus on Certainty in Wake of Uncertain Position Plan

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IRS plans to focus broadly on providing businesses additional certainty as the need for guidance becomes more critical in the wake of its plan to require taxpayers to disclose their uncertain tax positions, says IRS Chief Counsel Wilkins. “I think we are going to assign a high priority to reducing business uncertainty” even before the agency gets the initial disclosures under the new program, Wilkins says on a KPMG webcast. “We're not going to sit around and wait for the first round of UTP [statements] to decide how to devote resources.” Wilkins addresses significant changes IRS made in the two-week-old guidance, such as new language on privilege and a directive to agents on how to approach disclosed information.