IRS Issues Further Guidance on Exams Involving Uncertain Tax Positions

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The IRS Large Business & International Division issues a memorandum to provide further Schedule UTP, Statement of Uncertain Tax Position, guidance and procedures applicable to LB&I examinations not covered by May and August memorandums. The memorandum from Commissioner Heather Maloy requires LB&I examiners and specialists, and their respective team and territory managers, to complete a just-in-time UTP training session and the prerequisite tax reserve training prior to reviewing a return that includes a Schedule UTP. IRS's Large Business & International Division in the coming year will focus on better selection of cases to audit, more effectively and efficiently auditing the cases selected, and resolving issues wherever appropriate and possible, LB&I Commissioner Heather Maloy says. Maloy, speaking to the Tax Executives Institute annual conference, says LB&I in the past has addressed the need to improve the tools to get at noncompliance and find the highest compliance risk.