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TEI 73rd Midyear Conference 2023 - Developments in Reporting Uncertain Tax Positions

On December 22, 2022, the IRS issued final changes to Schedule UTP, Uncertain Tax Position Statement, applicable to taxable year 2022 returns to be filed and processed in 2023. TEI and other stakeholder groups vigorously contested the proposed changes, questioning not only the expedited manner in which the IRS sought to implement the changes, but also their substance. Despite our best efforts, the IRS chose to move forward with significantly enhanced UTP reporting requirements, and we have assembled a team of leading practitioners to help you understand their impact and approaches for complying with them. Our panelists will overview the history of Schedule UTP reporting and the significant accounting and legal issues the disclosures present. They will then identify recent changes to the schedule, explain the legal and procedural issues the enhanced disclosures present, and discuss approaches for complying with the new reporting requirements.

SPEAKERS: Sharon Katz-Pearlman, Shareholder, Greenberg Traurig; Shawn R. O'Brien, Partner, Mayer Brown LLP; David Gillman, VP-Tax, Telephone & Data Systems, Inc.; Jonathan A. Sambur, Partner, Eversheds Sutherland LLP

MODERATOR:  David Gillman, VP-Tax, Telephone & Data Systems, Inc.