Internal Revenue Service (IRS) Announcement 2010-9 proposes a new disclosure regime under which certain large business taxpayers would be required to report their uncertain tax positions (UTPs) on their annual business tax returns. In this article, Uncertain Tax Positions and the IRS Transparency Initiative: No Holds Barred, Deloitte summarizes certain information about the proposal, including:
Who must file, Types of UTPs to be disclosed,
When and where to disclose UTPs,
How to calculate the maximum tax adjustment,
and Potential impact on financial reporting.
The article includes responses to polling questions posed to executives during a related Dbriefs webcast, including the number of UTPs their organizations expect to disclose for tax year 2010 and how they might manage the new requirement. This article also contains resources from Deloitte and others for more information.
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