Practitioners Say Uncertain Positions Documents Answer Some Questions

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IRS's new draft schedule and instructions to report uncertain tax positions are administratively helpful and well thought out, but concerns remain about the use of the information and the scope and breadth of the proposal itself, practitioners tell BNA in interviews. Practitioners say Schedule UTP, Uncertain Tax Position Statement, closely reflects the plan originally outlined in Announcement 2010-9. Although some helpful technical clarifications have been made, “This document is not an effort to back away at all from what was in the original proposal,” says Mark Silverman, a practitioner with Steptoe & Johnson LLP. Concerns about the scope of the reporting requirement—and about what IRS will do with the information—“are still there,” he says.