Larry Gibbs discusses the new Schedule UTP, Uncertain Tax Position Statement, saying he thinks it will be the biggest compliance issue facing large corporations in 2011. "The biggest tax compliance issue for large corporations is likely to be the preparation of their year-end financial statements with their tax reserves in light of the Schedule UTP, and then later on the filing of their tax returns, including Schedule UTP," Gibbs said in January. "That was the biggest story probably this last year, and I suspect it's going to be a big story in 2011," he added.

IRS has announced its intent to use the Schedule UTP to start shifting some resources "downstream" from larger corporations to smaller publicly and privately held corporations, as well as passthrough entities, Gibbs said. "Whether we'll see that take place this year is a good question. I don't know. That's awfully quick for IRS to be moving the resources but it wouldn't surprise me if the service begins to do some things," he said. Gibbs said that while he is not sure if the activity in this area will be visible, he thinks the service will move forward with plans to expand the audit capability beyond just large corporations.