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The IRS’s Final UTP Disclosure Requirement

Implications of transparency initiative and enhanced tax governance


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With the IRS’s final uncertain tax position (UTP) disclosure requirement in place, certain large corporate taxpayers must report UTPs on their 2010 federal returns. In three articles Deloitte discusses the requirement and various implications.

The first two articles, U.S. Tax Reporting Requirements for Uncertain Tax Positions: An Historical Perspective and Uncertain Tax Positions and the IRS Transparency Initiative: No Holds Barred, explored IRS Announcement 2010-9, the IRS proposal for increased transparency, and the developments leading up to the proposal.

The third article Schedule UTP: The Next Step in Tax Governance and Transparency, explores:

  • Technical and practical issues of Schedule UTP
  • The policy considerations that shaped the final schedule
  • Actions taxpayers might take to prepare for reporting

These articles contain resources from Deloitte and others for more information.

Download the articles at the bottom of the page to learn more.

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