The IRS uncertain tax position initiative

The US Internal Revenue Service recently released Schedule UTP which requires certain large corporate taxpayers to report their uncertain income tax positions as part of their US federal income tax return. The schedule also requires a concise description of the uncertainty involved in each reported tax position. Both UK corporations that file a US federal income tax return and US subsidiaries of UK parent companies are potentially subject to this new reporting requirement. Interestingly, this reporting initiative is similar to a recommendation made in the UK by the Keith Committee in 1983.