1120 Sch. UTP

Uncertain Tax Position Statement

Agency
IRS
Revision
Rev. December 2022
Fillable fields
1060
Pages
3
Official source
IRS form page
Checked
October 21, 2026
Fill 1120 Sch. UTP online
Page 1 of form 1120 Sch. UTP

Schedule UTP (Form 1120): Uncertain Tax Position Statement

Schedule UTP (Form 1120) is the Uncertain Tax Position Statement. The About page says it 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.

The instructions say a tax position is reported when the corporation took it on a return for the current or a prior tax year and the corporation or a related party recorded a liability for unrecognized tax benefits for it in audited financial statements, or recognized the benefit because it expects to litigate.

The schedule says to file it with Form 1120, 1120-F, 1120-L, or 1120-PC. It is a corporate schedule, not an individual form. You can fill out the PDF free in your browser on this page and download the result without an account.

What's on Schedule UTP (Form 1120)

Header and page count

The entity's name as shown on page 1 of the tax return, its EIN, and a page count for each part, such as page 1 of 2 Part I pages.

Part I: current tax year

One row per uncertain tax position taken on the current return, numbered with a preprinted C, with columns (a) through (k).

Columns (b) to (h)

Primary IRC sections, revenue rulings or procedures, regulation sections, timing codes P and T, pass-through entity EIN, the major tax position box and the ranking of each position.

Columns (i) to (k)

The form or schedule, line number and amount where the tax position appears on the return.

Part II: prior tax years

Positions taken on a prior year's return that were not reported on an earlier Schedule UTP, numbered with a preprinted P, with an added column (l) for the year of the position.

Part III: concise descriptions

A concise description of each uncertain tax position, tied to its UTP number from Part I or Part II.

How to fill out Schedule UTP (Form 1120)

  1. 1

    Number and cite each position

    Number positions C1, C2 and so on without skipping or grouping. Enter up to three primary IRC sections, such as 61 or 263A, with no text like "IRC" or "Section". Columns (c) and (d) are for positions contrary to a rule or regulation.

  2. 2

    Columns (e) and (f)

    Check T for a temporary difference, P for a permanent difference, or both. If the position relates to a pass-through entity, enter its EIN, or "F" for a foreign entity without one.

  3. 3

    Columns (g) and (h)

    Check column (g) if the position's relative size is greater than or equal to 0.10 (10%). In column (h), rank all positions in Parts I and II together, using T for transfer pricing positions and G for all others.

  4. 4

    Columns (i) to (k)

    Enter the form or schedule and line number where the position appears and the amount reported on that line, for example Sch. M-3, line 20, for deferred income.

  5. 5

    Part II

    Report prior-year positions not already reported, continuing the number sequence from Part I with the P prefix. In column (l), enter a six-digit year and month, such as 202212.

  6. 6

    Part III

    Describe every position listed. The instructions say to include the relevant facts, the identity of the position and the nature of the issue, and that "Available upon request" is not an adequate description.

Why fill Form 1120 Sch. UTP on indox

You get the real form, filled in a browser tab, with nothing standing between you and the finished PDF.

  • Fill the form right in your browser, no software to install
  • Free to fill and free to download, with no account
  • The official blank straight from the IRS, not a copy someone retyped
  • Works on a phone, tablet or computer

How it is filed and related rules

Attach to the return

The instructions say to attach Schedule UTP to the corporation's income tax return and not to file it separately. A protective Form 1120, 1120-F, 1120-L, or 1120-PC also carries it when the four conditions are met.

Question on the return

A corporation filing Schedule UTP checks Yes on 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.

Forms 8275 and 8275-R

The instructions say a complete and accurate disclosure on Schedule UTP is treated as if the corporation filed Form 8275 or Form 8275-R for that position.

Amended returns

An amended return that claims the benefit of a reported position includes the disclosure. For carryovers of attributes such as net operating losses, the instructions describe an attached statement instead.

Older positions

The instructions say a tax position taken in a tax year beginning before January 1, 2010, is not reported.

Related forms

Who files Schedule UTP (Form 1120)?

  • Corporations filing certain returns

    The corporation files Form 1120, Form 1120-F, Form 1120-L, or Form 1120-PC.

  • Assets of $10 million or more

    The corporation has assets that equal or exceed $10 million. For Form 1120, the instructions point to the amount on page 1, item D.

  • Audited financial statements

    The corporation or a related party issued audited financial statements covering all or part of its operations for all or part of the tax year. The instructions say compiled or reviewed statements are not audited statements.

  • At least one reportable position

    The corporation has one or more tax positions to report. The instructions say not to file a blank Schedule UTP if there are none.

  • Affiliated groups

    The instructions say an affiliated group filing a consolidated return files one Schedule UTP for the group. An affiliate that files separately and meets the conditions files its own.

The instructions say a corporation files it for the current tax year when all four conditions below are met.

Official sources and the blank

Do it all with indox

View all 123 tools

Questions about Form 1120 Sch. UTP

Does every corporation file Schedule UTP?

No. The instructions limit it to corporations filing Form 1120, 1120-F, 1120-L, or 1120-PC with assets of $10 million or more, audited financial statements and at least one reportable tax position.

What if there are no uncertain tax positions?

The instructions say not to file a blank Schedule UTP if there are no tax positions to be reported.

Is a position reported again every year?

The instructions say a prior-year position already reported on a Schedule UTP filed with a prior year return is not reported again. If a transaction results in tax positions on more than one return, each is reported on Part I of the Schedule UTP attached to the return in which it is taken.

Who counts as a related party?

The instructions define it as any entity with a relationship described in section 267(b), 318(a), or 707(b), or any entity included in consolidated audited financial statements with the corporation.

Does Schedule UTP replace Form 8275?

For the positions it covers, the instructions say a complete and accurate disclosure on Schedule UTP is treated as if Form 8275 or 8275-R were filed, so a separate one is not needed for certain accuracy-related penalties.

What should the Part III description leave out?

The instructions say a concise description should not include an assessment of the hazards of a tax position or an analysis of the support for or against it.