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The IRS uncertain tax position initiative

Donald L Korb and James Gadwood examine this recent initiative and consider what it means for UK corporations

In 1983 the Committee on Enforcement Powers of the Revenue Departments (the ‘Keith Committee’) issued the first two volumes of its report on additional enforcement powers that should be conferred on the then Inland Revenue. Among the Keith Committee’s recommendations was ‘a statutory obligation to draw to the Inspector’s attention all occasions where in making a return the taxpayer takes the benefit of any doubt whether any item ought to be declared or any relief or deduction granted.’ Although many of the Keith Committee’s suggestions were eventually implemented this one was not.

Perhaps earlier this year someone in the US Internal Revenue Service (IRS) finally got around to reading the Keith Committee report and noticed this particular recommendation. Notwithstanding the fact that the recommendation was never adopted...

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