Skip to main content

Miller & Chevalier Disclosure of Uncertain Tax Positions Teleconference

Miller & Chevalier held a Tax Transparency teleconference about Announcement 2010-9 and the IRS's proposed disclosure regime for uncertain tax positions. The IRS announced a new disclosure regime that would require most large corporate taxpayers to disclose with their tax returns (1) all uncertain tax positions for which they created a financial accounting reserve (and certain other uncertain tax positions) and (2) for each disclosed position, the maximum exposure if the IRS were to successfully challenge the position. Taxpayers and their representatives have until March 29 to submit comments on the proposed regime, and Miller & Chevalier discussed the potential impact of the proposal and strategy for commenting on the proposal.