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2022 72nd Midyear Conference

M08 - Addressing Risk from Uncertain Tax Positions

Mar 21, 2022 1:00pm ‐ Mar 21, 2022 2:00pm


The resources being dedicated to identifying, documenting, and disclosing uncertain tax positions (UTPs) have been steadily increasing for several years, attributable, in part, to unprecedented new complexities in tax laws, incomplete guidance, and increasing demands for clarification from outside accountants. UTPs raise a variety of challenging issues many of which require judgment and all of which carry material consequences for errors. In this session, we’ve assembled a diverse group of seasoned tax and accounting practitioners to address what an in-house tax department should consider when facing risk attributable to uncertain tax positions. Our panelists will address UTPs arising in a variety of different contexts (e.g., uncertain tax authorities, unresolved controversies, tax planning), trends in documenting and substantiating UTPs, and the role of tax opinions and their impact on privilege claims to resist disclosure of confidential communications.

At the conclusion of this course, participants should:

  • Understand the financial accounting standards for reporting tax reserves;
  • Understand the U.S. federal income tax requirements to disclose uncertain tax positions and how to apply them in a variety of contexts;
  • Be aware of procedural issues surrounding the compelled disclosure of audit and tax accrual workpapers and how to navigate them in practice;
  • Understand the scope and limitations of and best practices for asserting privilege to protect against government attempts to compel disclosure of documents and other communications




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