Tax Controversy Updates: IRS releases draft uncertain tax position form and instructions

On April 19, 2009, IRS issued Announcement 2010-30 which released the draft Uncertain Tax Positions (UTP) form, accompanied by draft instructions. The draft schedule, Schedule UTP, and instructions provide a further explanation regarding the reporting of uncertain tax positions.

The instructions clarify who is required to file and what tax positions are required to be reported, how to determine a unit of account, how the maximum tax adjustment is computed and the impact of the new reporting requirements on other disclosure statements.

The IRS requested public comments on the draft schedule and instruction and set a deadline of June 1, 2010.