Dealing with the IRS Ruling on Uncertain Tax Positions

Starting with their 2010 tax returns, companies with assets of at least $100 million will need to provide concise descriptions of their uncertain tax positions, or UTPs, to the IRS. An uncertain tax position is one for which a taxpayer has recorded a reserve within its financial statements. Also included under the rubric "UTP" are positions for which an organization has not recorded a reserve because it expects to litigate the matter.