The Proposed Federal Schedule UTP and State Conformity: Implications for Taxpayers if States Require Similar Disclosure

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With the recent release of a draft “Schedule UTP”, the IRS continues its agenda to require disclosure of uncertain tax positions on federal corporate income tax forms. While the new schedule appears to exclude state-related uncertain tax positions, the question remains whether states will follow suit and require such disclosures on their own corporate income tax forms. In this article, the authors offer their assessment of what states are likely to do and discuss steps taxpayers could take to mitigate exposure.
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