Since Tax Year 2010, Schedule UTP has been used by certain corporations to report uncertain tax positions. Corporations filing Forms 1120, 1120-F, 1120-L, or 1120-PC must file Schedule UTP if total assets equal or exceed the applicable asset threshold for the tax year and the corporation reserved for a tax position in audited financial statements.
For tax years beginning in 2014 and later, the asset threshold for reporting uncertain tax positions on Schedule UTP (Form 1120) decreased to $10 million. Corporations meeting all other Schedule UTP filing requirements must file a Schedule UTP if total assets equal or exceed $10 million. This asset threshold decrease for tax year 2014 is the final phase of the five-year Schedule UTP filing requirement phase-in. The asset threshold for tax years 2010 and 2011 was $100 million, and it decreased to $50 million for tax years 2012 and 2013.