Learn how to prepare the schedules along with the associated disclosures and filings that accompany them.
It has been a little more than 15 years since the Schedule M-3 was added and over a decade since the IRS introduced these additional disclosures for tax positions. Both introductions were met with a bit of fanfare but in recent years these disclosure mechanisms have become routine while corporate examination rates have fallen. As the IRS gears up for additional funding and focuses a new light on corporate taxpayers, the agency has returned to these tax return disclosures for examination leads and penalty opportunities. This topic will help tax professionals understand the evolving purpose of these disclosures. The material will also explain how to prepare the schedules along with the associated disclosures and filings that accompany them. Understanding the purpose and filing requirements of these tax return disclosures can help taxpayers reduce audit risk and avoid penalties for improper filing. This information is critical for tax professionals who are responsible for these disclosures and their colleagues who manage tax risk and audit exposure.
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Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
History, Purpose, and Application of Schedule M-3 and Schedule UTP
- Purpose and Introduction of Schedule M-3
- Covered Entities
- Purposes and Introduction of Schedule UTP
- Covered Entities
- Common Issues and Topics
Preparation of the Schedules
- Preparing Schedule M-3
- ASC 730
- Preparing Schedule UTP
- Concise Descriptions
- ASC 74010
- Related Disclosures
Recent Changes and Enforcement Initiatives
- IRS Corporate Enforcement Initiatives
- International Transactions
- LB&I Directives and ASC Announcements
- Section 41 Credits
- Schedule M-3 and Partnership Capital Accounts
- CPAR Audit Regime
- Schedule UTP and Form 8275
- NonReciprocal Reporting Requirements
Penalties
- Form 8275
- Safe Harbors/Reasonable Cause
Conclusion
- A Renewed Approach to Schedules M-3 and UTP
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on June 28, 2021.
Call 1-866-352-9540 for further credit information.
- CA MCLE 1.5
- Lorman Education Services is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Anson H. Asbury, J.D., LL.M.
Asbury Law Firm
- Managing Shareholder, Asbury Law Firm
- Practice focuses on complex federal tax litigation and tax controversy
- He advises Fortune 50 companies on tax reporting, tax procedure, and IRS & state appeals processes; he also represents closely held partnerships, estates, and high net worth individuals in civil and criminal tax litigation
- 'Schedule UTP: The Early Returns Are In,' Journal of Accountancy, November 2012
- 'Schedule UTP Expands Its Reach for 2012 Filers, Current Accounts,' The Georgia Society of CPAs, March/April 2013
- Fellow, American College of Tax Counsel; fellow, American Bar Foundation; vice-chair, Court Practice and Procedure Committee, American Bar Association Section on Taxation; past chair, Atlanta Bar Association Tax Law Section
- Ranked among the best of his peers by Chambers USA, Best Lawyers in America, and Super Lawyers
- LL.M. degree, Georgetown University Law Center; J.D. degree, Penn State Dickinson Law; B.A. degree, Villanova University
- Can be contacted at 404-382-9942 or [email protected]
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