New Schedule UTP: “Uncertain Tax Positions In the Age of Transparency”

A taxpayer, when signing the jurat on the tax return, swears under penalties of perjury that the tax return is true, accurate, and complete. But, as a general rule, the taxpayer need not have a subjective belief that the tax position taken on the tax return is sustainable when making this sworn statement. Furthermore, tax advisors need not believe that a tax position is ultimately sustainable before they advise the client to take a position on a tax return.