What is clear is that corporations meeting the 2010 asset requirements will be required to list uncertain tax positions for which a taxreserve is recorded or for which the corporation does not record a reserve because it intends to litigate the position.
The instructions provide that the corporation has taken an uncertain tax position with respect to the amortization deduction in 2010 for which a taxreserve was established (in 2009), and consequently the corporation is required to disclose the position on the 2010 Schedule UTP.