True Partners Consulting’s Uncertain Tax Positions Services are designed to assist organizations in effectively managing audit and penalty risks resulting from the new UTP disclosure regime. Our experienced corporate tax advisors will review your potentially disclosable items, help you determine what should and should not be included on the Schedule UTP, complete the Schedule using appropriate disclosure language, and—where necessary and possible—provide appropriate documentation, including tax opinions, to reduce the risk of penalties, free of any conflict of interest.
Our approach starts by discussing with you all of the company’s potentially reportable transactions. After performing our own independent research, we will then make recommendations to you regarding what to disclose and how to make the disclosures. We also recommend which transactions can and should, in our view, be supported by an opinion—which we may prepare at your request. We will also work with you to develop an appropriate audit defense plan to address inevitable challenges by the IRS and state tax authorities, as well as a strategy to protect privileged documents.