The IRS should consider amending its draft revised Schedule UTP, Uncertain Tax Position Statement, due to the “significant burden” it places on taxpayers and practitioners, the AICPA wrote in a letter to the agency.
The agency’s revised instructions for the Schedule UTP would go into effect for the 2022 tax year (processing year 2023).
A major change of the IRS draft would require corporations to disclose “contrary” authorities, i.e., language that disagrees with the corporation’s stance on the Schedule UTP.
The AICPA urged the agency to remove the language “because the requirement is not supported by current law or IRS policy.”
If the IRS does move forward with the revisions as written, it should delay implementation to make it effective for the applicable tax year and not retroactive, the AICPA argued. Learn more.