AICPA Submits Comments on IRS Uncertain Tax Position Disclosure Proposal


Via the Journal of Accountancy

In January, in Announcement 2010-30, the IRS announced plans to make changes to how certain business taxpayers report uncertain tax positions.  The proposal included a requirement for taxpayers with assets of more than $10 million to file new Schedule UTP, Uncertain Tax Position Statement, if they have one or more uncertain tax positions.

The AICPA’s concerns about the proposal focus on six areas:

  • – The proposal potentially undercuts the integrity of the financial statement process;

  • – It will impose an increased burden and cost on taxpayers substantially disproportionate to any actual benefit to the IRS;

  • – It will create a new tension among and between taxpayers, tax advisers and the IRS, and alter the current self-assessment system;

  • – It will produce complexity and result in distortions that will impede the stated IRS goals;

  • – It will disproportionately impact small businesses; and

  • – It calls for taxpayer reporting at a higher level than mandated by Congress.


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