Academic journal article Journal of Accountancy

Uncertain Tax Positions Schedule to Debut for 2010; Comment Period Still Open

Academic journal article Journal of Accountancy

Uncertain Tax Positions Schedule to Debut for 2010; Comment Period Still Open

Article excerpt

The IRS extended until June 1 the comment period for its proposal to require large businesses to disclose uncertain tax positions and announced that it intends to make the requirement effective for tax years beginning in 2010.

The IRS said in Announcement 2010-17 in early March that, in response to requests from a number of groups, including the AICPA, for more time to study the proposal, the IRS extended the comment period. When the Service unveiled the proposal Jan. 26 in Announcement 2010-9, the IRS had set March 29 as the comment cutoff date.

The IRS anticipates that a draft new schedule and instructions it planned to release in April would answer many of the questions it has received about the proposal. The proposal would require businesses with more than $10 million in assets to disclose with their tax returns certain details about each uncertain tax position, defined as a position for which the taxpayer or a related entity has recorded a reserve in its financial statements under FASB Interpretation no. 48 (FIN 48), Accounting for Uncertainty in Income Taxes, or other accounting standards. (The provisions of FIN 48 are now codified in FASB ASC Topic 740.) Reportable uncertain tax positions would also include those for which taxpayers have not established a reserve because they expect to litigate the position or have determined the IRS has a general practice not to examine the position. …

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