The Final Draft of Schedule UTP for 2010 and The Latest IRS Guidance on Disclosing Your Uncertain Federal Income Tax Positions Firm
Overview:
The 2010 Schedule UTP and Instructions are now in final form. Certain corporate income taxpayers must now file this form and eventually many more will have to follow suit. Simultaneously IRS issued guidance explaining the changes it made - or did not make - to the draft Schedule UTP released in April and announcing changes to its “policy of restraint” plus an internal directive. Our program will cover those changes and their significance to you including:- Overview of 2010 Schedule UTP & Instructions
- Summary of the latest IRS guidance
- Commentary on issues for financial accounting and tax return reporting, including the impact on
privileges you may claim
- A look ahead
Agenda:
ALL TALKING POINTS:
- A Brief History Of Schedule UTP
- FIN 48
- Corporate Transparency
- A Brief History of the IRS's Policy of Restraint in requesting Tax Accrual Workpapers
- IRS's 2010 Announcements
- Schedule UTP and Instructions
- Who Must File & When
- What Must Be Reported
- Multi-Year Items & Transitional Year Items
- Beneficial Uses of Schedule UTP
- Announcement 2010-75 & Selected Issues Surrounding Schedule UTP
- Relief Granted by Announcement 2010-75
- Potential Overdisclosure or Underdisclosure or Overdisclosure of Uncertain Positions
- Schedule UTP and Potential Penalties
- How Announcement 2010-76 modifies the IRS's Policy of Restraint
- A Review of Privileges in Tax Advice and Tax Accrual Workpapers
- The Latest Developments in Work Product Privilege, including Deloitte and Textron
- A Consideration of Selected Privilege Issues in Complying with Schedule UTP
- The IRS's Directive A Look Ahead
- Schedule UTP and IRS's Prioritization of Audit
- Schedule UTP and IRS's Ability to Issuer Better Guidance Sooner
- The Impact of Schedule UTP on Tax Planning and Income Tax Audits
- Schedule UTP, Tax Information Exchange and the Adoption of Similar Disclosuresate by Foreign and State Tax Authorities
Who Should Attend:
- All Tax Executives
- Chief Financial Officers
- Chief Compliance Officers
- General Counsel
- Tax Counsel
- Tax Advisors
- Auditors
- Tax Attorneys
- CPAs
- Tax and audit professionals
In May 2010, J. Richard “Dick” Harvey was named the Distinguished Professor of Practice at the Villanova Law School/Graduate Tax …
Phillip A. Pillar is a Shareholder in the Philadelphia Office of Greenberg Traurig, LLP. Phil's practice concentrates on representing and …
Background Mike is a Director in KPMG’s Financial Services Practice. Prior to joining KPMG, Mike worked for 32 years for …
Course Level:
Intermediate
Advance Preparation:
Print and review course materials
Method of Presentation:
On-demand Webcast (CLE)
Prerequisite:
NONE
Course Code:
104095
Total Credits:
2.0 CLE
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SPEAKERS' FIRMS:
About Villanova University Law School
Website: https://www.law.villanova.edu/
About Greenberg Traurig, LLP
Website: https://www.gtlaw.com/
About KPMG
Website: https://www.kpmg.com/