Tax & Accounting Blog

Transfer Pricing Tops List of Leading UTP Disclosures

Global Tax Compliance, Tax Provision, Transfer Pricing, US Income Tax Compliance December 6, 2011

Internal Revenue Service Commissioner Douglas Schulman, speaking at the national tax conference of the American Institute of Certified Public Accounts said that of the approximately 1,500 disclosures of Uncertain Tax Positions received, transfer pricing, research and development credits and business expenses topped the list of disclosures.

The service views the UTP disclosures as a tool to point to returns requiring further examination, either signaling need for audit or exclusion.

 The IRS head reveals the goverment agency is working through a better process for identifying and centrally collecting returns with UTP schedules following the recent mandate of the September 2010 Schedule Uncertain Tax Positions. Schulman discusses his vision for leveraging technology to produce more accurate returns and dealing with more problems up-front noting: “We could shift resources to spend more money getting it right in the first place, and do less back-end auditing.”

Schulman’s full remarks can be found at:,,id=249453,00.html