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

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.

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