On September 24, 2010, the IRS issued the final Schedule UTP and
instructions that require corporations to report so-called
"uncertain tax positions," or UTPs. In conjunction with
finalizing the schedule, the IRS released Announcement 2010-75,
explaining the changes it made to the final Schedule UTP from the
draft schedule and instructions released April 29, 2010.
Additionally, the IRS issued Announcement 2010-76, which details
the IRS's revisions to its policy of restraint with regard to
seeking taxpayers' tax accrual workpapers during audit, as well
as an internal directive to the field which outlines the IRS'
plan for treating uncertain tax positions.
In a previous
On the Subject, McDermott Will & Emery reported on
the release of the Internal Revenue Service's (IRS) draft
schedule and instructions for reporting uncertain tax positions
(UTPs). Recently the IRS issued Announcement 2010-75, in which it
unveils many important changes to the schedule in response
