Jerald David August recently moderated and presented on the topic of "Required Disclosures of Potential Tax Liabilities to IRS and on Corporate Financial Statements" for the American Law Institute webcast on September 30, 2015. Mr. August spoke on "uncertain tax positions", tax opinions and the attorney-client privilege and work product doctrine on tax litigation matters related to tax accrual work papers and ASC 740-10 (FIN 48) work papers.
This webinar is now available on demand. If you would like to look at the program brochure please visit www.ali-cle.org
Why You Should Attend
For the past several years, the IRS has required corporations that meet a certain asset value threshold to file a Schedule UTP disclosing all "uncertain tax positions" (UTP) reflected on their corporate income tax returns for the current year. In addition, a Schedule UTP is required for prior tax years in which a reserve was recorded for a UTP that was included in audited financial statements. Corporations also must meet all reporting requirements for audited financial statements whether prepared under U.S. GAAP, IFRS, or other country-specific accounting standards.
Attorneys, tax advisors, and tax return preparers who are not aware of the complexities of Schedule UTP put their corporate clients at serious risk. A failure to disclose UTPs or to adhere to GAAP or applicable accounting and financial reporting standards may result in an IRS document request/summons to obtain the corporation's supporting tax documentation related to the establishment of reserves. It also may result in the imposition of back taxes, interest, and penalties.
Join a nationally-recognized tax practitioner and a corporate head of tax as they address the rigors of both making adequate disclosures under Schedule UTP and meeting GAAP or applicable accounting and financial reporting standards. Discussion will also cover the defense of an IRS document request by invoking either privilege or work product doctrines.
What You Will Learn
Topics will include:
- When are corporations required to file Schedule UTP?
- What are the Schedule UTP requirements?
- What are the relevant GAAP or applicable accounting and financial reporting standards?
- How to use attorney-client/accountant-client privileges and the work product doctrine to defend IRS document requests.
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