Proposed Reporting of Uncertain Tax Positions
Posted 3-18-2010 | By John Kammerer
The Internal Revenue Service (IRS) announced a proposal to require business taxpayers with assets of more than $10 million to report uncertain tax positions on federal income tax returns filed for calendar year 2010 or fiscal years beginning in 2010. The IRS invites the public to submit comments on the proposal by June 1, 2010. HLB Tautges Redpath in conjunction with HLB International is submitting comments regarding this proposal that would have a significant impact on many businesses.
The IRS is developing a schedule required for filing with the Form 1120, U.S. Corporation Income Tax Return, or other business tax returns. The schedule in development will require a description of each uncertain tax position for which the taxpayer or a related entity has recorded a reserve in its financial statements and the maximum amount of potential federal tax liability attributable to each uncertain tax position.
Currently, this proposal would affect businesses that prepare financial statements (or are included in the financial statements of a related entity that prepares financial statements), and businesses or related entities that determine its United States federal income tax reserves under FIN 48 or other accounting standards relating to uncertain tax positions involving United States federal income tax. However, the IRS is also requesting comments, in Announcement 2010-17, on what type of uncertain position should be reported by pass-through entities.
If you would like to submit comments, please include “Announcement 2010-9” in the subject line and email to: announcement.comments@irscounsel.treas.gov
Or send to:
Internal Revenue Service
CC:PA:LPD:PR (Announcement 2010-9)
Room 5203
P.O. Box 7604
Ben Franklin Station, N.W.
Washington, D.C. 20044.
All comments will be available for public inspection and copying.
For more information, please visit www.irs.gov or contact John Kammerer, CPA, at jkammerer@hlbtr.com.