Uncertain Tax Positions: New Schedule UTP Requirement for Many Companies in 2013

Making Complex Disclosure Decisions as IRS Reduces its Filing Threshold

Recording of a 110-minute CFP webinar with Q&A


Conducted on Wednesday, February 13, 2013
Recorded event now available


This teleconference will prepare corporate tax professionals who are reporting uncertain tax positions to the IRS to identify and understand Schedule UTP compliance challenges and anticipate potential questions upon an audit.

Description

Tax staffs for more, and smaller, companies should improve their familiarity now with the requirements of federal Schedule UTP. The IRS threshold for filing the form reporting uncertain tax positions declines to $50 million or less in assets in 2013 (for the 2012 tax year) and to $10 million in assets in 2015.

Companies must file Schedule UTP if they record a reserve for certain tax positions in their audited financials, or when they assess odds that a position will be litigated at better than 50%. With the filing threshold dropping next year, many more companies and their tax staffs must navigate IRS rules and FAQs.

Moreover, future IRS policy is worth consideration. Many observers feel the pace of filing Schedule UTPs on transfer pricing and other positions has been less than expected so far, leading to concerns about possible tougher enforcement by the Service. The time is now for a material briefing on Schedule UTP.

Listen as our presenter reviews the Schedule UTP rules in the contexts of lessons learned to date in preparing the schedule, and of evolving IRS oversight and examination policy.

Outline

  1. Rules pertaining to Schedule UTP
    1. Reduced filing thresholds for 2013 and 2015
    2. IRS regulations, announcements, FAQs
  2. Lessons learned from large corporations preparing Schedule UTP to date
  3. Issues arising from IRS exams of Schedule UTP

Benefits

The panel will analyze key issues such as:

  • Calculating the maximum amount for each uncertain tax position.
  • Meeting the requirement for a "concise description" of each reserved position.
  • Navigating the "more likely than not" standard.
  • Examining what is known now about how the IRS views sufficiency of Schedule UTPs so far and how workpapers are being treated.

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.

Upon completing this seminar, you will be better prepared to properly complete Schedule UTP as the IRS filing threshold declines and sweeps in more corporate taxpayers.

Faculty

Cherie Hennig, Associate Professor of Accounting
University of North Carolina at Wilmington, Wilmington, N.C.

She also is the author of a treatise, "Practical Guide to Schedule M-3 Compliance," 2nd edition, and of numerous articles on Schedule M-3 and Schedule UTP compliance that have appeared in trade publications.

Ordering

CFP Credit

Certified Financial Planner (CFP) credit hours

CFP Processing $35.00


Recorded Event

Includes full event recording plus handouts (available after live webinar).

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CD (Audio with Slide PDFs) $49.00 plus $9.45 S&H
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On-Demand Seminar - Audio Recording

Includes streaming audio of full program plus handouts (available 24 hours after live program).

Note: Self-study CPE, RTRP, and EA credits are not offered on on-demand webinars.

On-Demand Seminar Audio $49.00
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How does this work?

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Program Materials

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Program Materials

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CFP Credit

Strafford is registered with the Certified Financial Planner Board of Standards. The CFP board has granted 2 credits for this program.

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Federal Income Tax Advisory Board

David Bowen

Principal

Grant Thornton

Joseph Calianno

Partner, National Tax Practice

Grant Thornton

Edward Froelich

Of Counsel

Morrison & Foerster

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Partner

PricewaterhouseCoopers

Christian McBurney

Federal Tax Partner

Nixon Peabody

Alex Sadler

Partner

Ivins, Phillips & Barker

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Partner

Bingham McCutchen

Tom Windram

Managing Director & National Leader, Federal Tax Credits & Incentives

RSM McGladrey

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