Beginning with tax years starting January 1, 2010, corporations with assets in exess of $100,000,000 are required to complete Schedule UTP with its tax return. Schedule UTP discloses information regarding certain “uncertain tax positions” the corporation may have taken on its tax return and for which it established a reserve in their financial statements (or didn’t establish a reserve because the taxpayer expects to litigate the position.)
Today, the IRS issued Frequently Asked Questions on their website to supplement the draft instructions to Schedule UTP, and clarify the interplay between:
1) The standard for determining whether a tax position requires inclusion in Schedule UTP, and
2) The standard for determining whehter a tax position requires a reserve be established FIN 48 purposes on the audited financial statements.
See the FAQ here.