Federal tax compliance specialists may have thought they were well prepared to complete their first Schedule UTP starting next year, but recent developments involving safeguards of their internal tax workpapers make compliance more complicated and high-stakes.
 
Given the U.S. Supreme Court's decision to let the Textron ruling stand, tax pros must wrestle with difficult decisions in translating uncertain tax positions onto Schedule UTP. What information can justifiably be left off the schedule because it is part of current or potential litigation?
 
Further, to the extent that tax-related information is judged to either be shielded or not from disclosure, what are the logical steps for a corporate taxpayer to take next? The implications are huge, ranging from what competitors can learn to the potential for audits.