Current News | Public Companies Play Dangerous Game With the IRS
The IRS says incomplete descriptions are being used to mask transactions on the new Form UTP. The UTP is where public companies who have FIN 48 declarations in their Securities filing declare those same "Uncertain Tax Positions" to the IRS. The IRS says these incomplete descriptions will be viewed unfavorably.
GF&R's position:
GF&R's Jason Redman says "Unfortunately by the time uncertain tax positions have made it to the Securities filings, its really too late to plan around the Form UTP. The planning opportunity is now - before the position is finalized and before the opportunity to improve the position is lost. Auditors expose positions, they don't plan around them. Now is the time to talk to your tax advisor about remeditating uncertain tax positions so that when smaller public companies have this requirement to complete Form UTP, they are prepared. Fancy wording on the Form UTP clearly is not the work around for the issues."