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9 DePaul Bus. & Comm. L.J. 349 (2010-2011)
Schedule UTP: An Insider's Summary of the Background, Key Concepts, and Major Issues

handle is hein.journals/depbcl9 and id is 355 raw text is: Schedule UTP: An Insider's Summary of the Background, Key Concepts, and Major Issues J. Richard (Dick) Harvey, Jr.* ABSTRACT A former IRS Commissioner has called Schedule UTP the big- gest change in tax administration in the last 50 years. Others have made less flattering comments, but most everyone working in the corporate tax community would admit it has been a big deal. Based upon the author's perception as a senior IRS official, this article is intended to be a comprehensive discussion of three topics. First, it will summarize what led the IRS to require the filing of Schedule UTP. Second, it will discuss the key concepts, including why certain provisions were adopted (e.g., the much misunderstood expect to litigate provision). And finally, there will be a discus- sion of the major issues, including in some cases the author's views on such issues. The article is written for several audiences, including: (i) corpo- rate tax professionals who already have a working knowledge of Schedule UTP and should be most interested in the discussion of major issues and possibly the theory behind the expect to litigate provision; (ii) students and academics who should be interested in the entire article; and finally (iii) government officials who should be interested in techniques corporations may use to avoid disclo- sure, the definition of reserve, whether Schedule M-3 should be modified, and several other sections. INDEX 1. Introduction, Purpose of Article, and Intended Audience 2. Quick Summary of Schedule UTP 3. Background that Led to Schedule UTP * Copyright 2011 by J. Richard (Dick) Harvey, Jr. The date of this article is April 1, 2011. Since August 2010, the author has been the Distinguished Professor of Practice at the Villanova University School of Law and Graduate Tax Program (rharvey@law.villanova.edu). Immedi- ately prior to joining the Villanova faculty he was the Senior Advisor to IRS Commissioner Shulman and worked extensively on the development of Schedule UTP, offshore tax evasion, and other international projects. Professor Harvey joined the IRS upon retiring from Price- waterhouseCoopers (PwC) as Tax Partner and Leader of PwC's U.S. Banking and Capital Mar- kets Tax Practice. While at PwC, he specialized in FIN 48 and consulted with the FASB during its development. Professor Harvey also served in the U.S. Treasury Department's Office of Tax Policy during the drafting and implementation of the 1986 Tax Reform Act.

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