This Schedule UTP Form 1120 guide explains the IRS Uncertain Tax Position Statement. Schedule UTP reports the uncertain tax positions covered by its applicable instructions. Financial statement reporting and tax return facts must be reviewed together to determine whether a position is reportable. The schedule is not a list of every theoretical question about a return.
Reviewed October 31, 2026. This is an independent guide. The version and availability information below identifies the IRS documents used for this page.
What Schedule UTP Form 1120 does and who prepares it
A corporation covered by the reporting rules supplies the required uncertain tax position information.
For the connected reporting route, see Form 1120. Keep the role of that document separate from the task explained on this page.
| Official form | Form 1120 (Schedule UTP) |
|---|---|
| IRS title | Uncertain Tax Position Statement |
| Guide period | the applicable reporting period |
| Target version | Dec 2022 |
| Availability | Current IRS catalog PDF |
| Last checked | October 31, 2026 |
Get the Schedule UTP Form 1120 PDF and check its status
Use the IRS source to confirm the document before completing a real filing. The download link is a reference to the official file; it is not a statement that every copy inside the PDF may be printed and submitted. Follow any instructions about electronic filing, scannable copies, recipient copies or attachments.
Which version of Schedule UTP Form 1120 should you use?
This form follows a revision or continuing-use format rather than a new title for every calendar year. Check the revision printed on the document and the period requested inside it. A revision date, transaction date and tax year are different pieces of information. The current document should be read with the instructions that apply to the actual transaction or return.
Records to gather for Schedule UTP Form 1120
- Financial statement tax reserve records.
- Position analysis.
- Relevant return calculations.
- Reporting threshold workpapers.
- Required concise descriptions.
Keep a working reconciliation with these records. It should show the source of each reported item, any correction made before filing and the reason a different amount appears on a connected form. This is especially useful when a statement is corrected or a prior-year balance continues into the current calculation.
How to work through Schedule UTP Form 1120
- Confirm applicability. Start with the purpose, filer category and version of the form. Complete any eligibility or applicability question before spending time on the numerical calculation.
- Prepare the source workpapers. Gather the records listed below and reconcile their totals. Keep prior-year balances, current-year transactions and estimated payments separate where they serve different purposes.
- Complete dependent calculations first. When a line refers to another form, schedule or worksheet, finish that supporting calculation first. Preserve any classification, limitation and carryforward information.
- Follow the line sequence. Use the actual line labels and arithmetic in the applicable form. A line number from an older version may refer to something different after a revision.
- Reconcile the filing package. Check names, identifying numbers, tax periods, totals and required attachments. Then use the filing method, signature process and deadline that apply to this filer and form.
Form-specific IRS instructions and reporting details
The following points retain the operative wording of the IRS documents linked above. Read each point with its stated conditions and the applicable form version. References to another form or section describe a connected requirement; they do not mean that every reader must file every referenced document.
Schedule UTP asks for information about tax positions that affect the U.S. federal income tax liabilities of certain corporations that issue or are included in audited financial statements and have assets that equal or exceed $10 million.
A corporation must file Schedule UTP for the current tax year if: 1. The corporation files Form 1120, U.S. Corporation Income Tax Return; Form 1120-F, U.S. Income Tax Return of a Foreign Corporation; Form 1120-L, U.S. Life Insurance Company Income Tax Return; or Form 1120-PC, U.S. Property and Casualty Insurance Company Income Tax Return; 2. The corporation has assets that equal or exceed $10 million; 3.
The corporation or a related party issued audited financial statements reporting all or a portion of the corporation’s operations for all or a portion of the corporation’s tax year; and 4. The corporation has one or more tax positions that must be reported on Schedule UTP. Do not file a blank Schedule UTP if there are no tax positions to be reported. Attach Schedule UTP to the corporation's income tax return. Do not file it separately.
A taxpayer that files a protective Form 1120, 1120-F, 1120-L, or 1120-PC must also file Schedule UTP if it satisfies the four requirements set forth above. A corporation required to file Schedule UTP must also check “Yes” to Form 1120, Schedule K, Question 14; Form 1120-F, Additional Information, Question AA; Form 1120-L, Schedule M, Question 15; or Form 1120-PC, Schedule I, Question 13.
Additional reporting conditions
Form 1120-L or Form 1120-PC, is at least $10 million. Form 1120-F. The assets of a corporation filing a Form 1120-F equal or exceed $10 million if the higher of the beginning or end of year total worldwide assets of the corporation reported on Form 1120-F, Schedule L, line 17, would be at least $10 million if the corporation were to prepare a Schedule L on a worldwide basis. Affiliated groups. An affiliated group of corporations filing a consolidated return will file one Schedule UTP for the affiliated group.
The affiliated group need not identify the member of the group to which the tax position relates, or which member recorded the liability for unrecognized tax benefits for the tax position. Any affiliate that files its U.S. federal income tax return separately and satisfies the requirements set forth above must file a Schedule UTP with its return setting forth its own tax positions.
Corporation B determines that the appropriate unit of account for GAAP financial reporting purposes is the functional expenditures, based on the amount of its expenditures, the anticipated credits to be claimed, its previous experience, and the advice of its tax advisors. Based on the unit of account used for financial reporting purposes, Corporation A must use each project as its unit of account for Schedule UTP reporting, and Corporation B must use functional expenditures as its unit of account for Schedule UTP reporting, regarding the research and development credit.
Calculations and supporting information
Form 8275 or Form 8275-R need not be filed to avoid certain accuracy-related penalties with respect to that tax position. For tax positions contrary to a rule otherwise reportable on Form 8275, you must identify the statutory provision on Schedule UTP, Parts I and II, in column (b); and the revenue ruling, revenue procedure, or other guidance in column (c).
For tax positions contrary to a regulation otherwise reportable on Form 8275-R, you must identify the statutory provision on Schedule UTP, Parts I and II, column (b); and enter the full regulation citation in column (d) (see Specific Instructions, later). For all tax positions otherwise reportable on Form 8275 or Form 8275-R, the concise description of UTPs on Schedule UTP, Part III must include all the information required under those forms.
Failure to provide a complete and accurate disclosure of the tax position on Schedule UTP will not satisfy the section 6662 adequate disclosure requirements for Form 8275, 8275-R, or tax positions reported on Schedule UTP.
Exceptions and related reporting
A complete and accurate disclosure of a tax position on Schedule UTP, Form 8275, or Form 8275-R must be included in an amended return that is filed to claim the benefit of the tax positions reported on these disclosure forms. If an amended return is filed to carryover attributes such as net operating losses or tax credits arising from tax positions reported in prior filings, the disclosure forms do not need to be completed.
Instead, attach a statement to the amended return that identifies each tax position, the amount, the nature of the disclosure, the form used to report the disclosure, and the tax year in which the tax position originates.
Example 12. Corporate merger. On June 30, 2022, MergerCo merges into AcquiringCo, in a transaction in which AcquiringCo survives. MergerCo's tax year ends on that date. After the merger, AcquiringCo records an unrecognized tax benefit with respect to a tax position that is taken on MergerCo's final return in its audited financial statements. That tax position must be reported on Part I of the Schedule UTP filed with MergerCo's 2022 tax return even though the unrecognized tax benefit was recorded by AcquiringCo.
AcquiringCo should not report the tax position on the Schedule UTP filed with its 2022 tax return because MergerCo's final return is a prior year tax return on which the tax position was reported.
Further form details
Columns (i) Through (k) Identify the location of the tax position and amount of the income tax benefits (see the definition of size earlier) reported on the tax return. Enter the form number or schedule and the line number in columns (i) and (j) and the amount of the item in column (k). For an expense item, report in column (k) the amount reported on the line of the form, schedule, or attached statement that includes the tax position taken.
If the tax position relates to an item of deferred income or unearned revenue, report in columns (i) and (j) the schedule or form and line number where the item is reported (for example, Sch. M-3, line 20, or Sch. L, line 21). Report in column (k) the amount reported on the line of the form, schedule, or attached statement that includes the tax position taken.
Complete Part II to report tax positions taken by the corporation in a prior tax year that have not been reported on a Schedule UTP filed with a prior year’s tax return. Do not report a tax position taken in a tax year beginning before January 1, 2010. See Transition rule under Reporting Uncertain Tax Positions on Schedule UTP, earlier.
A practical example
A corporation reviews its financial statement tax positions and the applicable reporting rules. The preparer identifies the positions that must be disclosed and prepares the required schedule descriptions from the supported facts.
This example illustrates the order of the review. It does not assume an unverified deduction, exemption, treaty rate or final tax amount. The applicable form instructions and the actual records determine the result.
Common mistakes to avoid with Schedule UTP Form 1120
- Check applicability before listing positions.
- Follow the requested description and ranking rules.
- Keep confidential supporting analysis separate from the actual information required on the schedule.
Questions about Schedule UTP Form 1120
Does receiving or downloading this form mean I must file it?
A corporation covered by the reporting rules supplies the required uncertain tax position information. The form purpose and the applicable filing or furnishing conditions determine the action. Downloading a blank PDF does not itself create a filing obligation or establish eligibility for a tax benefit.
Is the revision date always the same as the tax year?
No. Some forms show a tax year, while continuing-use forms show a revision date and ask separately for the reporting period. Check the actual document and instructions. Do not relabel a payment or transaction solely because it was reported in a later calendar year.
What should I do if the underlying information is wrong?
Check applicability before listing positions. Keep the original record and the correction trail. The issuer correction process, an amended return and an updated certificate can be different procedures. Choose the process that matches the document and the actual error.
Which records should I keep with the completed form?
Retain the source documents, applicable worksheets, submitted version and filing or furnishing confirmations. For this form, the working file should include financial statement tax reserve records, position analysis, relevant return calculations. Keep continuing balances and prior-year support for as long as they remain relevant under the applicable recordkeeping rules.
Related forms and next steps
Use these guides when the connected issue applies to your records. Each page has its own purpose, reporting year and availability status.