The IRS has released statistics for the 2010 to 2014 tax years relating to Schedule UTP (Uncertain Tax Position) filings, showing that there were 6,320 uncertain tax positions reported in 2014. The statistics show a steady increase in the reported positions, which totaled 4,740 in 2010, although this may also be attributed to the fact that the number of Schedule UTP filers has increased from 2,143 in 2010 to 2,747 in 2014. It is not surprising that the number of Schedule UTP filers have increased from 2010 to 2014 since reporting requirement has decreased from corporations with at least $100 million in assets (2010) to $10 million in assets (2014). However, the increase in filers has not affected the average number of uncertain tax positions per filer, which remains stable at 2.3. The most common types of UTPs reported continues to be IRC section 41 research credit and IRC section 482 transfer pricing, which collectively account for over half of all reported uncertain tax positions. The chart is available here for your consideration.
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