The Internal Revenue Service may have eased up on its call for details about shaky tax positions, but senior executives are jittery about the new requirement nonetheless.

In a recent poll of 1,100 business leaders by KPMG’s Tax Governance Institute, nearly half said they’re worried about a new schedule added to 2010 corporate tax returns calling for a list of tax positions where companies have some doubts about how well those positions will hold up under examination or litigation. Companies are required by the IRS to file the new Schedule UTP to provide a “concise description” of each position and rank them in order of risk magnitude.

It’s that concise description that is keeping executives up at night, according to the KPMG poll; 44 percent said that aspect of their requirement is the biggest source of their worry. Nearly half are also worried the UTP requirement will create tensions among tax advisers, tax departments, and external audit firms. And despite the IRS’s latest pledge that it won’t ask for information that is protected by attorney-client privilege, 42 percent of executives said the promise gives them no comfort that IRS agents won’t demand the information anyway.

Hank Gutman, KPMG tax principal and director of the Tax Governance Institute, and former chief of staff of the U.S. Congressional Joint Committee on Taxation, said the IRS proved to be responsive to a number of concerns that were raised when it first unveiled the new requirement as a proposal. The ultimate requirement, for example, doesn’t require companies to provide any data to the IRS that they’re not already gathering and managing for financial reporting purposes, especially the dollar amounts that taxpayers consider to be at risk with individual tax positions.

Gutman said there could be some good to come from the UTP disclosures, given the IRS plan to form a “triage team” that will study disclosures and look for common themes. “A lot of positions that taxpayers are uncertain about arise because there’s a lack of guidance from the IRS in those areas,” he said. “To the extent a lot of the same issues show up, that will indicate to the Service that this is an area where more guidance is necessary.”

Nearly 40 percent of executives said their companies had already taken steps to prepare for the UTP requirement; and nearly 30 percent said the new filing requirement is driving interest in IRS provisions such as pre-filing agreements, advance pricing agreements, and the compliance assurance program to reduce the uncertainty that must be reported under the UTP.