In his prepared remarks to the New York State Bar Association Taxation Section Annual Meeting, Internal Revenue Service (IRS) Commissioner Doug Shulman highlighted new reporting requirements. The new requirements will affect business taxpayers who have both a financial statement prepared under FIN 48 or other similar accounting standards reflecting uncertain tax positions and assets greater than $10 million.

Under the Announcement, these taxpayers would be required to disclose uncertain tax positions annually in the form of a concise description of those positions and the maximum amount of U.S. income tax exposure if the taxpayer's position is not sustained.

During the presentation, Shulman clarified that the proposal does not require the taxpayer to disclose the taxpayer's risk assessment or tax reserve amounts. He explained that the IRS is asking for a list of issues that the taxpayer has already prepared for financial reporting purposes in order to improve the efficiency and effectiveness of tax examinations. As part of this proposal, the IRS would otherwise retain its longstanding policy of restraint as it applies to tax accrual workpapers.