Government Still Looking at Asset Threshold Issue in Uncertain Tax Positions Proposal

The government continues to wrestle with the question of how a $10 million asset threshold for those required to disclose uncertain tax positions under a new proposal will apply to…

IRS Seeking Targeted Information Regarding Uncertain Tax Positions, Sullivan & Cromwell Says

The Internal Revenue Service appears to be requiring taxpayers to provide significantly pinpointed information describing their uncertain tax positions under a proposal mandating disclosure of…

Recent IRS Moves on Uncertain Tax Positions, Foreign Bank Reporting Seen Having Transfer Pricing Implications

Recent actions by the Internal Revenue Service on uncertain tax positions and by Congress on reporting and disclosure requirements for foreign banks have implications for transfer pricing, KPMG LLP practitioners…

Uncertain Tax Positions Reporting Not Road Map for Adjustments, IRS Chief Counsel Says

Internal Revenue Service Chief Counsel William Wilkins April 23 reiterated that the agency does not plan to use the information it gets from taxpayers on uncertain tax positions as a road map for…

IRS Not Planning to Use Uncertain Tax Position Reports as Starting Point for Examinations

The Internal Revenue Service does not plan to use the information it gathers from requiring taxpayers to report their uncertain tax positions as an automatic starting point for examinations, IRS Large and…

IRS Uncertain Positions Documents Answer Some Questions, Leave Others, Practitioners Say

The draft schedule and instructions that taxpayers would use to report uncertain tax positions, unveiled by the Internal Revenue Service April 19, are administratively helpful and well…

IRS Unveils Draft Schedule, Instructions for Reporting Uncertain Tax Positions

The Internal Revenue Service April 19 unveiled the eagerly awaited draft schedule and instructions that taxpayers would use to report their uncertain tax positions under…

ANALYSIS: Who Needs ‘Customers’? The Real Import (or Export) of IRS Announcement 2010-9 on ‘Uncertain Tax Positions’

If anything explodes the fiction that the U.S. Internal Revenue Service and the taxpayer—particularly the corporate taxpayer—are in a constructive partnership…

IRS Considering Valuation Issues with Uncertain Tax Position Proposal, Official Says

The Internal Revenue Service is thinking about issues surrounding the valuation of the maximum amount of potential federal tax liability attributable to each…

IRS Says Uncertain Tax Positions Proposal Not for 2009 Returns, Seeks More Comments

The Internal Revenue Service said March 5 it is extending the time for submission of comments on its recent proposal for mandatory reporting of uncertain tax…

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