Instructions For Schedule Utp Draft - Uncertain Tax Positions Statement

Column C. Timing Codes

Check T for temporary differences, P for permanent differences, or check both T and P for a tax position

that creates both a temporary and permanent difference. Categorization as a temporary difference,

permanent difference, or both must be consistent with the accounting standards used to prepare the

audited financial statements.

Column D. Pass-Through Entity EIN

If the tax position taken by the corporation relates to a tax position of a pass-through entity, enter the EIN

of the pass-through entity to which the tax position relates. For example, if the corporation is a partner in

a partnership and the tax position involves the partner’s distributive share of an item of income, gain, loss,

deduction, or credit of the partnership, enter the EIN of the partnership. A pass-through entity is any

entity listed in section 1(h)(10). If the tax position is not related to a tax position of a pass-through entity,

leave this blank. Enter F if the pass-through entity is a foreign entity that does not have an EIN.

Column E. Administrative Practice

Check this box if the tax position must be reported because it was determined the IRS would not

challenge the position upon examination based on IRS administrative practice.

Column F. Maximum Tax Adjustment

Enter the maximum tax adjustment amount for each tax position that is not a valuation tax position or a

transfer pricing tax position. If the tax position is a valuation tax position, enter V for valuation followed by

a number representing the ranking of the tax position within all reported valuation tax positions (e.g., V1).

If the tax position is a transfer pricing tax position, enter TP for transfer pricing followed by a number

representing the ranking of the tax position within all reported transfer pricing tax positions (e.g., TP1).

Begin with the number 1 for the tax position with the largest estimated potential tax adjustment or, if

applicable, the largest reserve, and do not skip any whole numbers.

Specific Instructions for Part II

[This section will not be completed in 2010]

Part II Uncertain Tax Positions For Prior Tax Years

When to Complete Part II

Part II is used to report tax positions taken by the corporation in a prior tax year that have not been

reported on a Schedule UTP filed with a prior year’s tax return.

Information From Related Parties

Check this box if the corporation was unable to obtain sufficient information from one or more related

parties and was therefore unable to determine whether a tax position taken in a prior year’s tax return is

required to be reported on Part II of this schedule.

Column A. UTP Number

Continue the numeric sequence based on the last UTP number entered on Part I. For example, if the last

UTP listed on Part I is 10, enter 11 for the first UTP listed on Part II. Assign a new number to each tax

position that is listed in Column G.

Column B. Primary IRC Sections

Refer to the instructions for Part I Column B.

Column C. Timing Codes

Refer to the instructions for Part I Column C.

Column D. Pass-Through Entity EIN

Refer to the instructions for Part I Column D.

Instructions For Schedule Utp Draft - Uncertain Tax Positions Statement - 2010 Page 8