SCHEDULE UTP DISCLOSURE REQUIREMENTS AND REPORTING OF UNCERTAIN TAX POSITIONS 682 A.
companies may be required to implement new international standards for income tax accounting, particularly when accounting for uncertain tax positions
The FASB's stated goal with FIN 48 was to reduce diversity in practice, and to that end it prescribes a specific model for recognizing and measuring uncertain tax positions
In the recognition phase, any intercompany transaction that could lead to an adjustment of income by the IRS or a foreign tax authority is considered to be an uncertain tax position
If the taxpayer's FIN 48 workpapers demonstrate that the taxpayer believed that a particular uncertain tax position
was likely to be sustained, then this fact would represent positive evidence that the taxpayer did in fact believe that its position was correct.
Based on those principles, the IRS designed schedule UTP to report basic information regarding a corporation's uncertain tax positions
on a self-assessment tax system.
Additionally, in connection with the reversal of the accounting for the Uncertain Tax Position
Reserve liability as previously recorded, the Company expects that based on federal income tax returns as filed, an additional $24.
The schedule must also include a concise description of the uncertain tax position
By refusing to define an uncertain tax position
and instead requiring all issuers to document every tax position at a MLTN standard, FIN 48 is clearly more demanding, prescriptive, and burdensome for issuers than FAS 5.
1) In January 2010, the IRS announced a proposal to require large corporations to report uncertain tax positions
on the new Schedule UTP, Uncertain Tax Position
Statement, to be filed with their annual tax returns.
In a nutshell, 2010-9 would require a concise description of each uncertain tax position
for which the taxpayer has recorded a reserve in its financial statements under the Financial Accounting Standards Board's FIN 48 interpretation.
Note: On April 22, 2011, the Institute submitted comments and recommendations for additional guidance about the reporting requirements for uncertain tax positions
on Schedule UTP, Uncertain Tax Position