Uncertain Tax Positions: Evolving Risks for U.S. Companies
Making Complex Disclosure Decisions In Light of New Developments
Recording of a 110-minute CLE webinar/teleconference with Q&A
Conducted on Tuesday, August 3, 2010
Recorded event now available
This CLE webinar will prepare corporate tax professionals to reconcile evolving new compliance and reporting decisions with the IRS policy on reporting uncertain tax positions. The panel will provide a framework for tax executives to make disclosure decisions in various scenarios.
Description
Federal tax compliance specialists may have thought they were well prepared to complete their first Schedule UTP starting next year, but recent developments involving safeguards of their internal tax workpapers make compliance more complicated and high-stakes.
Given the U.S. Supreme Court's decision to let the Textron ruling stand, tax pros must wrestle with difficult decisions in translating uncertain tax positions onto Schedule UTP. What information can justifiably be left off the schedule because it is part of current or potential litigation?
Further, to the extent that tax-related information is judged to either be shielded or not from disclosure, what are the logical steps for a corporate taxpayer to take next? The implications are huge, ranging from what competitors can learn to the potential for audits.
Listen as our panel of veteran federal tax advisors explores critical new decisions that await you in reporting uncertain tax positions and prepares you to make the best choices for your company.
Outline
- Key terms of IRS Announcement 2010-9
- Disclosure of “uncertain tax positions” on new schedule accompanying returns
- Disclosure of maximum federal tax liability for each position
- Consideration of possible failure-to-file or non-disclosure penalties
- Potential implications of Textron case
- Workpapers must be viably tied to litigation to be protected
- Bridging the Textron case and Schedule UTP
- What FIN 48-related tax positions can be shielded from disclosure, because are part of current or pending litigation?
- What tax positions have no justifiable argument against disclosure
- How to report such positions on Schedule UTP
- Best practices going forward
- If your company does have to disclose sensitive positions
- If it doesn’t have to report positions
Benefits
The panel will address these and other key issues:
- Complying with Schedule UTP requirements and completing the new uncertain tax position disclosure form.
- Understanding the Textron decision: What information now can and cannot be protected?
- Connecting legal protections with Schedule UTP: Which tax positions can be left off?
- Best practices going forward: What sensitive information is and isn't disclosable?
Upon completing this webinar, you will be thoroughly briefed on potential new disclosure requirements in reporting uncertain tax positions and better prepared to utilize best practices, regardless of whether certain workpapers and other information must or need not be disclosed.
Faculty
Michael J. Desmond,
Partner
Bingham McCutchen, Washington, D.C.
His practice focuses on federal tax controversies, administrative dispute resolution and tax policy counseling for a broad range of corporate clients. He previously served as tax legislative counsel for the Treasury Department, supervising a staff of attorneys and accountants developing administrative guidance.
Lawrence M. Hill,
Partner and Chair, Tax Controversy and Litigation Group
Dewey & LeBoeuf, New York
He is a prominent attorney in major IRS controversy, tax litigation and white collar investigation matters. He previously worked as a trial attorney and national tax shelter project attorney with the IRS Office of Chief Counsel, and as a special assistant U.S. attorney.
Edward L. Froelich,
Of Counsel
Morrison & Foerster, Washington, D.C.
He has represented corporations, partnerships, and individuals in the administrative and litigation stages of a federal tax controversy. He devotes substantial time to following developments in privilege and work product issues as they affect tax controversies, and is a frequent speaker on topics such as privilege, work product, FIN 48, and low-income taxpayer litigation issues.
Kim Boylan,
Partner
Latham & Watkins, Washington, D.C.
Her practice centers on tax controversy, including litigation, sophisticated accounting policy issues, audits and administrative appeals. She previously was a partner at Mayer, Brown, Rowe & Maw.
Ordering
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Customer Reviews
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Supervalue
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Bradley Arant Boult Cummings
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Global Tax Management
Timely coverage of a complicated subject.
William Ahlstrom
Kerber Eck & Braeckel
Real life examples that we could relate to. Keep up the great work.
Brett Terrebonne
Entergy
Federal Income Tax Advisory Board
David Bowen
Principal
Grant Thornton
Joseph Calianno
Partner, National Tax Practice
Grant Thornton
Of Counsel
Morrison & Foerster
George Manousos
Partner
PricewaterhouseCoopers
Federal Tax Partner
Nixon Peabody
Tax Controversy Partner
Crowell & Moring
Of Counsel
Skadden Arps
Tom Windram
Managing Director & National Leader, Federal Tax Credits & Incentives
RSM McGladrey
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