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Final Regs Issued Requiring Uncertain Tax Position Disclosure Statement - Emil Estafanous, CPA : Emil Estafanous, CPA

Final Regs Issued Requiring Uncertain Tax Position Disclosure Statement

On Dec 13, a IRS released final regulations requiring some companies to record a Schedule UTP, disclosing their capricious taxation positions when filing a lapse (T.D. 9510). The final regulations adopt regulations due in Sep (REG-119046-10), with one change relating to a effective date. For before coverage, see “IRS Issues Proposed Regs Requiring Disclosure of Uncertain Tax Positions.”

In Jan 2010, a IRS announced that it designed to start requiring certain corporate taxpayers to divulge capricious taxation positions annually in their sovereign income taxation returns. For a 2010 taxation year, companies filing Form 1120, word companies filing Form 1120-L or 1120-PC, and unfamiliar companies filing Form 1120-F contingency avowal their capricious taxation positions on Schedule UTP when a association or a associated celebration released audited financial statements and when a association has both (1) one or some-more capricious taxation positions that contingency be reported on Schedule UTP (as tangible by a IRS in a instructions for Schedule UTP) and (2) sum resources equal to or in additional of $100 million. The sum item threshold will be reduced to $50 million in 2012 taxation years and to $10 million starting with 2014 taxation years. The IRS is deliberation either to extend UTP stating to other taxpayers over those remarkable above for 2011 or after years.

The final regulations are effective on their announcement in a Federal Register.

AICPA Concerns

Throughout a phenomenon of a IRS’ capricious taxation position stating plan, a AICPA has lifted countless concerns and done many specific recommendations per a IRS’ strange proposal. These concerns include:

  • The weight that will be placed on smaller taxpayers when a devise is entirely phased-in in 2014 since a threshold was not increased;
  • The intensity weight a devise might place in destiny years on pass-through entities and tax-exempt organizations;
  • Duplicative stating and a ultimate advantage to a supervision of a information received.

The AICPA will continue to lift suitable issues with a IRS on this matter and pull for a investigate duration as summarized in a initial criticism letter, according to Edward Karl, AICPA clamp president–Taxation. It will continue to promulgate a concerns and disciple for a members per a avowal of capricious taxation positions, Karl said.

About Emil Estafanous, CPA
Certified Public Accountant (CPA) Tax Professional committed in representing taxpayers and resolving their tax problems.

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