Perspective
Apr. 16, 2011
Schedule UTP: Is the Internal Revenue Service Playing Fair?
A new reporting requirement is viewed by many corporate taxpayers as unnecessary and intrusive. By Ivan Morales and Michael Liu of Baker & McKenzie.
In an effort to streamline tax administration and enforcement, the Internal Revenue Service (IRS) has started requiring many corporate taxpayers to file a Schedule UTP (uncertain tax position statement) with their federal income tax returns. The new schedule requires corporate taxpayers to disclose uncertain tax positions taken on their tax returns and to rank those tax positions in terms of relative size. Many taxpayers consider t...
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