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Email The IRS announced a proposal that would require any corporate or partnership business taxpayer with total assets in excess of $10 million to disclose to the IRS their "uncertain tax positions" for which reserves are maintained under FIN 48 by the taxpayer or a related entity. https://www.cadwalader.com/resources/clients-friends-memos/irs-proposes-reporting-requirements-for-uncertain-tax-positions-under-fin-48