A contested new requirement related to uncertain tax positions (UTPs), or how tax positions affect corporations’ income tax liability, will largely remain intact. In October, the IRS announced changes to UTP reporting. But many affected taxpayers and tax professionals objected to the requirement that they would have to cite “authoritative sources” contrary to the positions they’ve taken. The IRS rejected calls to scrap or delay implementation of the new rule in its Dec. 22, 2022, final draft. However, it altered the Schedule UTP instructions to say that only Internal Revenue Bulletin guidance and court decisions would have to be cited as sources. Contact the Cg Team to discuss. © 2022
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