Ilya A. Lipin


The benefits to corporate taxpayers from the continuing additions to disclosure requirements have not been obvious. Despite expenditures by corporate taxpayers on compliance, there is evidence that the Service has not been using all of the information it receives from additional disclosure forms.28 Duplicative disclosures of the same or similar tax information that lead to additional costs are of immediate concern to the corporate taxpayer.29 The estimated corporate taxpayers’ compliance tax burden is summarized in Appendix 1. Part II of this article describes in detail key existing reporting requirements such as reportable transaction disclosure statement and Form 8886, disclosure statements and Forms 8275 and 8275-R, net income (loss) reconciliation disclosure form and Schedule M-3, and disclosure of uncertain tax positions through Schedule UTP. Part III of this article highlights the duplicative disclosures required by these forms and schedules and proposes means to reduce redundant duplicative reporting. The duplicative disclosures are thereafter summarized in Appendix 2. Part IV discusses possible solutions to mitigation of duplicative reporting requirements and suggests creation and implementation of a comprehensive disclosure form that should replace the existing reporting mechanism in order to achieve the desired transparency and efficiency. Lastly, Part V concludes this article.

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