IRS Proposes Rules Allowing Uncertain Tax Position Requirement

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IRS proposes regulations (REG-119046-10) allowing the agency to require corporations to disclose their uncertain tax positions, in a move that practitioners say makes clear that IRS intends to move ahead with the disclosure proposal unveiled in January. The rules represent the next step toward formal implementation of the plan, which mandates that taxpayers with audited financial statements and $10 million or more in assets reveal their uncertain positions on a schedule accompanying their tax returns. In a preamble to the new guidance, IRS says that when finalized, the rules will apply to returns filed for tax years beginning after Dec. 15, 2009, and ending after the date the final rules are published.