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The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
Column (a). UTP No. Column (e). Major Tax Position related parties and was therefore unable
to determine whether a tax position
Enter a number in column (a) for each Check this box if the relative size of the
taken on its prior year's tax return is
tax position reported. The UTP numbers tax position is greater than or equal to
required to be reported in Part II of this
on Part I, column (a), include a 0.10 (10%). The relative size of a tax
schedule.
preprinted “C” prefix to indicate that they position is the amount computed by
are positions for the current tax year. A dividing the size of that position by the
corresponding UTP number with the sum of all of the sizes for all of the tax Column (a). UTP No.
letter “C” prefix will be used on Part III positions listed on Parts I and II. Continue the numeric sequence based
for reporting the concise description of Disregard expectation to litigate on the last UTP number entered on Part
the tax position. Begin with the number positions for column (e) purposes. I. For example, if the last UTP listed on
1, do not skip any whole numbers, do Round amounts using rules similar to Part I is 3, enter 4 for the first UTP listed
not enter extraneous characters, and do the rules in the Instructions for Form on Part II. The UTP numbers on Part II,
not duplicate any numbers (for example, 1120 (or the instructions for the column (a), include a preprinted “P”
C1, C2, C3, where the letters “C” are applicable tax return) for rounding dollar prefix to indicate that they are positions
preprinted on the schedule and the amounts. for prior tax years. A corresponding UTP
numbers are entered). number with a letter “P” prefix will be
Column (f). Ranking of Tax used on Part III for reporting the concise
Column (b). Primary IRC Sections Position description of the tax position. Do not
skip any whole numbers, do not enter
Provide the primary IRC sections (up to Enter a letter and a ranking number for extraneous characters, and do not
three) relating to the tax position. Enter each tax position. Use the letter T for duplicate any numbers (for example,
one primary IRC section in each box (for transfer pricing positions and the letter P4, P5, P6, where the letters “P” are
example, “61,” “108,” “263A,” etc.). Do G for all other tax positions. preprinted on the schedule and the
not include descriptive references or
numbers are entered).
any other text such as “IRC,” “Section,” Rank all tax positions in Parts I and II
or “IRC Sec.” Beneath each primary IRC together, regardless of type. Starting Column (b). Primary IRC Sections
section, you may enter the applicable with the largest size, assign the number
IRC subsections (for example, (f)(2)(A) 1 to the largest, the number 2 to the next See the instructions for Part I, column
(ii)), using the preprinted parentheses. If largest, and so on, in order. This (b).
there are more than four subsection number is the ranking number for the
components, list only the first four. tax position. Expectation to litigate Column (c). Timing Codes
positions may be assigned any ranking See the instructions for Part I, column
Column (c). Timing Codes number. (c).
Check “T” for temporary differences, “P”
for permanent differences, or check For example, the corporation has one
Column (d). Pass-Through Entity
both “T” and “P” for a tax position that transfer pricing tax position and two
creates both a temporary and other tax positions. The transfer pricing EIN
permanent difference. Categorization as position is the largest and one of the See the instructions for Part I, column
a temporary difference, permanent other tax positions is the expectation to (d).
difference, or both must be consistent litigate position. The expectation to
with the accounting standards used to litigate position is assigned a rank of 2. Column (e). Major Tax Position
prepare the audited financial Enter “T1”for the transfer pricing
statements. position, “G2”for the expectation to See the instructions for Part I, column
litigate position, and “G3”for the second (e).
Column (d). Pass-Through Entity other tax position.
Column (f). Ranking of Tax
EIN
Part II. Uncertain Tax Position
If the tax position taken by the
Positions for Prior Tax
corporation relates to a tax position of a See the instructions for Part I, column
pass-through entity, enter the employer Years (f).
identification number (EIN) of the When To Complete Part II Column (h). Year of Tax Position
pass-through entity to which the tax
position relates. For example, if the Complete Part II to report tax positions
corporation is a partner in a partnership taken by the corporation in a prior tax List the prior tax year in which the tax
and the tax position involves the year that have not been reported on a position was taken and the last month of
partner’s distributive share of an item of Schedule UTP filed with a prior year’s that tax year, using a six-digit number.
income, gain, loss, deduction, or credit tax return. Do not report a tax position For example, enter 201712 for tax years
of the partnership, enter the EIN of the taken in a tax year beginning before ending December 31, 2017, and
partnership. A pass-through entity is any January 1, 2010. See Transition rule 201808 for tax years ending August
entity listed in section 1(h)(10). If the tax under Reporting Uncertain Tax 2018.
position is not related to a tax position of Positions on Schedule UTP, earlier.
a pass-through entity, leave this blank.
Enter “F” if the pass-through entity is a Information From Related Parties
foreign entity that does not have an EIN. Check the box at the top of Part II if the
corporation was unable to obtain
sufficient information from one or more
Instructions for Schedule UTP (Form 1120) -5-
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