An article in the April issue of the Journal of Accountancy documents questions and answers with IRS Commissioner Doug Shulman, (www.journalofaccountancy.com/Issues/2010/Apr/20102509.htm). The second question reads, "What can you tell CPAs who are concerned about the proposed reporting regime for uncertain tax positions?" His answer is basically that we need to be glad the IRS isn't exercising its legal authority and demanding all the FIN 48 working papers! Being the nice folks they are, the commissioner says they are only asking for a list of positions and the maximum exposure to those positions....for the time being!
Agree with this or not, monitoring tax compliance has become the burden of the return preparer under this proposal. Work to prepare the list of uncertainties and their maximum exposure will increase return preparation time considerably, not to mention the time that will be consumed by IRS follow-up inquiries and audits. On top of this, we can expect that failure to provide a complete list of uncertain tax positions could bring huge penalties. When is enough enough?
Speak now or forever hold your peace!The AICPA's Tax Division is collecting input to formulate a response to the IRS proposal at MemberinputonAnnouncement2010-9@aicpa.org. We can also respond directly to the proposal at www.irs.gov. Let your voice be heard!
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