Uncertain Tax Positions

IRS Proposes New Tax Return Disclosure of Uncertain Tax Position Starting 2010 Centered Around Financial Statement Tax Reserves and Separately Wins Battle Over Right to Summons Tax Workpapers in Textron.

In January 2010, the Internal Revenue Service ("IRS") announced a new tax return disclosure requirement for "uncertain tax return positions" ("UTPs") that are reflected by tax reserves for U.S. Federal income tax liability recorded for financial statement purposes. The IRS' objective in requiring UTP disclosure is to gain greater visibility of tax return positions that represent potential underreporting of tax.

UTP reporting on new Schedule UTP, released by the IRS on April 20^th in draft form, generally applies starting 2010 to business entities that both report Federal income tax reserves in an audited financial statement and have assets in excess of $10 million. Initially, only certain corporate return filers are subject to the new disclosure rule in the 2010