Reglamento de organización y funciones (rof)

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Every year, thousands of the nation’s largest corporations are required report to the I.R.S. whether they, have reduced their tax bills by using questionable accounting strategies.

They have to supply an estimate of how they might owe if those strategies failed to withstand an audit.

They even have to set aside enough money to pay the government if their claims are found to be improper.

But the corporations are not obliged to reveal precisely what those uncertain tax positions are and if the I.R.S. does not manage to ferret them out challenge them before the three-year statute of limitations expires, the companies can Keep the money.

Now, the Internal Revenue Service is calling an
…ver más…

Shulman said.

Though transparency may be considered a virtue by the person collecting taxes, it is viewed as a menace to the people whose job is to minimize them. Mr. Shulman`s initiative, which even his critics concede he has the authority to enact, has set off an anguished response from corporations and accountants. They predict that it will make a cumbersome system even more costly and confrontational.

David A Lifson, former president of the New York State Society of Certified Public Accountants, cautions that the will allow tax authorities to bully taxpayers by. According to S.E.C. filings, at least 11 corporations reported last year that their potential tax liabilities totaled 10 percent or more of their revenue. Starwood Hotels and Resorts posted a $999 million tax reserve, 21 percent of its revenue of $4.7 billion; Agilent Technologies reserved $930 million, 21 percent of its revenue of $4.48 billion.

After he was sworn in as commissioner in 2008, Mr. Shulman found that auditors sometimes spent 2.5 percent of their time searching often in vain for what those positions might be. He decided that more disclosure would eliminate “a tremendous wastes of time for the auditors the taxpayer.”

As now written, Mr. Shulman`s plan would force corporations to file a new form, schedule UTP, providing a concise description of any uncertain positions and their rationale for

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