As corporate taxpayers use increasingly complicated transactions to minimize their tax liabilities, the Internal Revenue Service has a harder time identifying, understanding and investigating transactions that might warrant audit adjustments. Indeed, Commissioner Douglas Shulman recently reported that IRS examiners expend a quarter of the time spent on corporate audits trying to identify “uncertain tax positions” taken by the corporation.1
In an effort to increase transparency, the IRS recently released Schedule UTP, through which certain business taxpayers will be required to report uncertain tax positions with their tax returns. While the introduction of Schedule UTP is likely to reduce the chance that dubious transactions will go unexamined, it remains to be seen how auditors will use the increased information available to them.
Background
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
LexisNexis® and Bloomberg Law are third party online distributors of the broad collection of current and archived versions of ALM's legal news publications. LexisNexis® and Bloomberg Law customers are able to access and use ALM's content, including content from the National Law Journal, The American Lawyer, Legaltech News, The New York Law Journal, and Corporate Counsel, as well as other sources of legal information.
For questions call 1-877-256-2472 or contact us at [email protected]
