In January 2010, the IRS announced a new tax return schedule that would require certain  taxpayers to disclose information regarding their uncertain tax positions (UTP). Schedule UTP generated (and continues to generate) considerable discussion in the state tax community. Currently, there are already a number of required disclosures to state tax authorities. This session will examine current federal disclosure regimes, including UTP, and the likely imposition of similar requirements by the states, including possible disclosure requirements in the context of an audit.