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Schedule UTP and Schedule M-3:Recent IRS Actions

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.

99 minutes
Course Exam
Certificate of Completion
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Why Lorman?

Over 34 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 34 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

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

This course was last revised on June 28, 2021.

Call 1-866-352-9540 for further credit information.

  • AIPB 1.5
     
  • This program is acceptable for 1.5 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     
  • AK CLE 1.5
     
  • Alaska attorneys may receive 1.5 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
     
  • AL CLE 1.6
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.6 hours credit.
     
  • AR CLE 1.5
     
  • This course has been approved for 1.5 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.5
     
  • The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.5
     
  • Lorman Business Center, LLC. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • CT CLE 1.5
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
     
  • HI CLE 1.5
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
     
  • IL CLE 1.5
     
  • This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.5
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.5 hours of CLE credit under M. Bar R. 5.
     
  • ND CLE 1.75
     
  • North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.75 hours of CLE credit.
     
  • NH MCLE 1.6
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 98 Minutes.
     
  • NJ CLE 2.0
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 2.0 hours of total CLE credit.
     
  • PA CLE 1.5
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 1.5
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
     
  • VT CLE 1.5
     
  • This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hour(s) of CLE credit. Please note: Attorneys may only claim 6 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
     
  • WI CLE 2.0
     
  • This program qualifies for 2.0 hour(s) of ondemand CLE through the WI Board of Bar Examiners.
     
  • WV MCLE 2.0
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 2.0 MCLE hours.
     

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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  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • ME CLE 1.5
     
  • NJ CLE 2.0
     
  • VT CLE 1.5
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 34 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.

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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Why Lorman?

Over 34 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.

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Product ID: 407634
Published 2021
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