The IRS recently released Schedule UTP filing statistics for the 2012 tax year. The statistics are not complete as returns from some late fiscal year filers and others still have not been processed. The Schedule UTP filing statistics include updated totals for the 2011 tax year, originally reported here.
As of December 2013, the IRS was able to report the following:
- 1,743 taxpayers filed Schedule UTP with their 2012 returns.
- 4,166 uncertain tax positions were reported for 2012, down from 5,980 in 2011.
- The percentage of taxpayers who filed Schedule UTP in multiple years was 55% for the 2012 tax year, down from 77% in 2011.
- The average number of uncertain tax positions per taxpayer was 2.4 in 2012.
- 42% of Schedule UTP returns included only one uncertain tax position
- 55% of taxpayers filing Schedule UTP in 2012 were publicly traded companies.
- The most frequently reported code sections underlying uncertain tax positions for 2012 were
- § 41 Research Credit (22%),
- § 482 Transfer Pricing (19%), and
- § 263 Capitalization (4%).