WASHINGTON (CN) – Corporations will have to disclose uncertain tax positions-those that are not certain to be accepted by taxing authorities-annually in their federal income tax returns, according to new rules adopted by the Internal Revenue Service.
A tax position is considered to be uncertain if it is more likely than not that the relevant taxing authority will reject the deduction, claim or interpretation taken by the filer based on case law, and regulatory advisories issued by state and federal agencies.
The filing requirement will be met by a Schedule UTP (uncertain tax position) which is to be submitted when filing a return. For the 2010 tax year, the rule only applies to taxpayers that issue audited financial statements and whose assets are greater than $100 million. In 2012 the threshold will drop to $50 million and to $10 million in 2014.
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