IRS Updates Schedule UTP Filing Statistics From 2011 Tax Year

• 1,677 taxpayers have filed Schedule UTP for TY2011. This is lower than preliminary totals previously reported because they included all returns with a UTP, the revised total removes duplicate filings. This total includes primarily calendar year filers, it will increase as fiscal year filers continue to be received.

• 82% of all returns filed with Schedule UTP were filed by IC taxpayers.

• 4,211 tax positions have been disclosed on Schedule UTPs for TY 2011.

• Includes 936 prior-year positions reported on Part II.

• Returns filed by CIC taxpayers with a Schedule UTP averaged 3.8 uncertain tax positions per Schedule, while returns filed by IC taxpayers with a Schedule UTP averaged 2.0 positions per Schedule.

• 44% of all Schedule UTP returns filed included only one uncertain tax position.

Schedule UTP TY2010 Filing Statistics

• 2,356 taxpayers filed Schedule UTP for TY2010.

• 79% of all returns filed with Schedule UTP were filed by IC taxpayers.

• 4,712 tax positions were disclosed on Schedule UTPs for TY 2010.

• Returns filed by CIC taxpayers with a Schedule UTP averaged 3.1 uncertain tax positions per Schedule, while returns filed by IC taxpayers with a Schedule UTP averaged 1.9 positions per Schedule.

• 49% of all Schedule UTP returns filed included only one uncertain tax position.

• The top three code sections reported by UTP filers are IRC 41, 482 and 162. Analysis of UTP filers' concise descriptions revealed that the third highest primary IRC section is actually IRC 263 capitalization.

• Transfer Pricing and Research Credit comprise 43% of all disclosed uncertain tax positions.