In itself, the requirement to file Schedule UTP doesn't add significantly to the finance department's workload, says Ray Sadowski, senior vice president and chief financial officer with Phoenix-based ., a distributor of electronic components, such as connectors and semiconductors, with $19 billion annual revenue. "There's some additional burden, because now you have to fill out a form that you didn't before. But, it's not onerous."

UTP issues were listed by CFOs, however, as among this year's greatest tax policy concerns earlier this year.

Of course, as with many undertakings it's not until one's immersed in the process that the larger questions arise. "People filed, and did the best they could, but the form elicited a lot of questions," says John A. Eliason, a Dallas-based tax partner with the law firm of Gardere Wynne Sewell LLP. In March that addresses some of those questions.

Probably the most significant clarification will help taxpaying firms that were in a net-operating loss or credit carryforward position in the years leading up to the effective date of UTP reporting, and that also had an uncertain tax position embedded within the NOL or credit carryforward, says Ken Kuykendall, a Chicago-based partner and U.S. tax accounting services leader with accounting firm PwC.

Say a company had a tax loss in 2009 that it could carry forward to 2010, along with an uncertain tax position from 2009. The company utilized the NOL in 2010, at which point the IRS' requirement to disclose UTPs had kicked in. The initial instructions for Schedule UTP left some question as to whether the company also would have to report the 2009 UTP. With the FAQ, "the IRS clarified that it was only looking for UTPs created beginning in 2010," Kuykendall.