IRS Issues Draft Schedule, Instructions for Uncertain Tax Positions

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IRS unveils the eagerly awaited draft schedule and instructions that taxpayers would use to report uncertain tax positions. In Announcement 2010-30, the agency invites comment and adds that the form and instructions will only be finalized after IRS receives and considers all comments, not only on the draft documents, but on the proposal itself. The instructions to the form, now known as Schedule UTP, Uncertain Tax Position Statement, flesh out the requirements—posited in January—that taxpayers must report these positions, include concise descriptions, and tell the government the maximum amount of tax exposure associated with a position. IRS says in the instructions it has reserved on the question of penalties.