The IRS is seeking public feedback on proposed changes to the UTP form.


The IRS is seeking public feedback on proposed changes to the UTP form.

The IRS thinks the draft modifications to Schedule UTP and its instructions will benefit the form.

For the 2022 tax year (the processing year 2023) Schedule UTP and the UTP Instructions, taxpayers have until the end of the day on November 18 to comment on the proposed changes.

Certain corporations have reported uncertain tax positions on Schedule UTP since the 2010 tax year. According to the IRS, corporations filing Forms 1120, 1120-F, 1120-L, or 1120-PC must submit Schedule UTP if their total assets match or surpass the applicable asset threshold for the tax year and they made a provision for a tax position in their audited financial statements.

Schedule UTP’s draft revisions and accompanying instructions, in the IRS’s opinion, will make the form more beneficial. For instance, a new field for the additional dollar amount of the taken uncertain tax positions is one of the form’s modifications. Additionally, new columns will be added for tax positions reported on Schedule UTP as opposed to Form 8275, Disclosure Statement, or Form 8275-R, Regulation Disclosure Statement, to identify the regulations or rulings that conflict with the positions taken on the tax return. Finally, the IRS said the updated Schedule UTP instructions include more relevant examples and offer improved guidance on what qualifies as an adequate disclosure for the concise description.

Stakeholders can email the IRS Large Business and International Division with their opinions on the changes at by November 18 at the latest.

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