Announcement 2010-9 explains the potential content of a schedule that will require certain business taxpayers to report uncertain tax positions on their tax returns and invites public comments on the IRS' approach.
Part IV. Items of General Interest Postponement of Certain Correction of Publication This Announcement discusses the poten- Tax-Related Deadlines by tial content of such a schedule and invites Accordingly, the publication of the final public comment on the Service’s proposed Reason of a Federally regulations (T.D. 9443), which were the approach. The schedule will require the Declared Disaster or subject of FR Doc. E9–767, is corrected annual disclosure of uncertain tax posi- Terroristic or Military Action; as follows: tions in the form of a concise description of Correction On page 2370, column 3, in the pre- those positions and information about their amble, under the paragraph heading “Ex- magnitude. The proposal does not require Announcement 2010–8 planation of Revisions”, last paragraph of the taxpayer to disclose the taxpayer’s risk the column, third through twelfth lines, assessment or tax reserve amounts, even AGENCY: Internal Revenue Service the language “Example 9. Example 9, though the Service can compel the pro- (IRS), Treasury. which reflects current IRS practice, ex- duction of this information through a sum- plains the impact of disaster relief on mons. United States v. Arthur Young, 465 ACTION: Correction to final regulations. installment agreement payments that be- U.S. 805, 815 (1984). While the Service come due during the postponement period. intends to require the reporting of uncer- SUMMARY: This document contains a Example 9 explains that the affected tax- tain tax positions, the Service is propos- correction to final regulations (T.D. 9443, payer’s obligation to make installment ing to otherwise retain its existing pol- 2009–8 I.R.B. 564) that were published in agreement payments is suspended during icy of restraint as described in Announce- the Federal Register on Thursday, Jan- the postponement period. Example 9 fur- ment 2002–63, 2002–2 C.B. 72, and IRM uary 15, 2009 (74 FR 2370) relating to ther explains that,” is corrected to read 4.10.20. postponement of certain tax-related dead- “Example 8. Example 8, which reflects lines either due to service in a combat current IRS practice, explains the impact BACKGROUND zone or due to a federally declared dis- of disaster relief on installment agreement aster. The regulations reflect changes in Uncertain Tax Positions payments that become due during the post- the law made by the Victims of Terrorism ponement period. Example 8 explains that Tax Relief Act of 2001, the Tax Extenders The United States federal income tax the affected taxpayer’s obligation to make and Alternative Minimum Tax Relief Act system relies on taxpayers to make a self- installment agreement payments is sus- of 2008 (TEAMTRA), and current IRS assessment of tax and to file the appropri- pended during the postponement period. practice. ate form of return that shows the facts upon Example 8 further explains that,”. which tax liability may be determined and DATES: This correction is effective on De- assessed. Section 601.103 of the Proce- LaNita Van Dyke, cember 17, 2009, and is applicable on Jan- dure and Administration Regulations. To Chief, Publications and uary 15, 2009. discharge its obligation to fairly and uni- Regulations Branch,
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