The IRS has announced that it is considering changes to reporting requirements regarding business taxpayers’ uncertain tax positions.  It plans to develop a schedule that will require the annual disclosure of uncertain tax positions in the form of a concise description of those positions and information about their magnitude.

The Service suggests the new schedule be filed by a business taxpayer with total assets in excess of $10 million if the taxpayer has one or more uncertain tax positions of the type required to be reported on the new schedule.  The initiative is clearly piggy-backing on FASB Interpretation No. 48 (FASB ASC 740-10), which is referenced several times in the notice.

The full text of the notice, IRS Announcement 2010-9, which contains a more detailed discussion of the proposal, is posted at http://www.irs.gov/pub/irs-drop/a-10-09.pdf.

The public is invited to submit comments on the proposal described in the Announcement by March 29, 2010.  Instructions for filing comments are included at the end of the Announcement.  NSAC thanks David Antoni and KPMG for calling this Announcement to our attention.