The IRS has released statistics for the 2010 to 2014 tax years
relating to Schedule UTP (Uncertain Tax Position) filings, showing
that there were 6,320 uncertain tax positions reported in 2014. The
statistics show a steady increase in the reported positions, which
totaled 4,740 in 2010, although this may also be attributed to the
fact that the number of Schedule UTP filers has increased from
2,143 in 2010 to 2,747 in 2014. It is not surprising that the
number of Schedule UTP filers have increased from 2010 to 2014
since reporting requirement has decreased from corporations with at
least $100 million in assets (2010) to $10 million in assets
(2014). However, the increase in filers has not affected the
average number of uncertain tax positions per filer, which remains
stable at 2.3. The most common types of UTPs reported continues to
be IRC section 41 research credit and IRC section 482 transfer
pricing, which collectively account for over half of all reported
uncertain
