Exempt Organizations Advisory - IRS Chief Counsel Speaks on Uncertain Tax Positions

Catherine W. Wilkinson (cwilkinson@steptoe.com)
Suzanne Ross McDowell (smcdowell@steptoe.com) 

As reported in prior Exempt Organizations Advisories, earlier this year the IRS developed a proposal to require certain taxpayers to report their uncertain tax positions. In Announcement 2010-17, the IRS requested comments regarding the application of this proposal to tax-exempt organizations. The IRS has announced that for 2010 the proposal would only apply to corporations with assets exceeding $10 million that file a version of Form 1120. Yesterday, in a webinar on the proposal, William Wilkins, Chief Counsel of the IRS, said that he would not be surprised if the IRS didn’t address the applicability of the proposal to tax-exempt organizations for “some time to come.”

An earlier report of the disclosure requirement is available here.