The Internal Revenue Service has issued Announcement 2010-30 together with a new proposed “Schedule UTP — Uncertain Tax Position Statement” on which most large corporations will be required to disclose and describe “uncertain tax positions” that affect their federal income tax liability. This new disclosure requirement is intended to improve taxpayer compliance by essentially providing the IRS with a road map for its examination of otherwise hidden tax issues and opaque transactions.
A corporation must file Schedule UTP with its income tax return if any of the following apply:
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