The Internal Revenue Service has published its proposed schedule and proposed instructions for how companies will be required to report where they have uncertain positions in their corporate tax returns.

In IRS Announcement 2010-30, the IRS says any corporate taxpayer, including insurance companies, with both uncertain tax positions and assets of $10 million or more would be required to file “Schedule UTP.” The filing requirement will not apply to real estate investment trusts or regulated investment companies, pass-through entities, or tax-exempt organizations until later, the IRS said.

The draft schedule calls for a tabular disclosure of individual uncertain positions, a “concise” description of each issue, a citation from the Internal Revenue Code that pertains to each uncertain position, and the maximum tax adjustment that could arise if the position didn’t hold up under examination. The schedule also asks if the company was unable to get the information it needed from related parties to determine if a particular position should be regarded as uncertain.

The draft instructions indicate a company will be required to report a position on Schedule UTP if the corporation or a related party has recorded a reserve for the position in an audited financial statement, or if it did not book a reserve because it planned to litigate the matter. The instructions say companies must report positions that are taken within 60 days of filing the tax return, and it provides detailed guidance on how to view and manage timing differences between tax filing and financial reporting dates.

Companies can take a look at the proposed schedule and instructions and comment on them to the IRS through June 1. In the meantime, the IRS is studying the extent to which the new requirement might overlap other existing requirements, and how to phase in the requirement for non-corporate entities.