Skoda Minotti

Taxpayers with assets over $10 million and with at least one uncertain tax position that is required to be disclosed on the proposed new form

AFFECTING:

IRS Considering Heightened Disclosure of Taxpayers’ Uncertain Tax Positions

DETAILS:

On January 26, 2010, the Internal Revenue Service issued Announcement 2010-9, in which the Service has indicated that it is considering changes to reporting requirements regarding certain taxpayers’ uncertain tax positions. The Service is developing a new tax-reporting schedule with which taxpayers would report with their annual federal income tax return their uncertain tax positions and the potential magnitude of tax positions.

In announcing the changes it is considering, the Service refers to the requirement under Financial Accounting Standards Board Interpretation No. 48, Accounting for Uncertainty in Income Taxes, an Interpretation of FASB Statement No. 109 (“FIN 48”),1 that taxpayers identify and quantify their uncertain tax positions for financial accounting purposes. The Service believes that the information reported under FIN 48 would assist in the examination of tax returns by bringing to light areas of interest or magnitude to warrant further inquiry, as well as assisting examination teams in identifying all issues more efficiently.

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