IRS Entices Employees to Disclose Sensitive Information

International Tax Review
April 1, 2011

Douglas S. Stransky was quoted and pictured in an article published on April 1, 2011 in International Tax Review entitled "IRS Entices Employees to Disclose Sensitive Information." The article discusses recent whistleblower regulations and other new IRS initiatives designed to encourage informants to disclose information to U.S. tax authorities that leads to the recovery of additional tax dollars.

In the article, Mr. Stransky notes that "[w]ith respect to companies, the potential for large reward amounts [under the whistleblower program] means that more employees may have an incentive to act in their own self-interest and drop a dime on their employers. . . . In light of all the focus on ensuring increased compliance, companies should already have policies and procedures in place. . . . Obviously, if a company has not yet responded to minimise the risks inherent in non-compliance, [these recent developments] should be additional incentive to take immediate action."

With respect to the new IRS Schedule UTP that goes into effect for certain companies this year, Mr. Stransky notes that uncertain tax positions that might be disclosed on Schedule UTP ". . . could be exactly the type of information that informants submit to the IRS [so] companies should ensure that their tax positions have been thoroughly examined internally, which would include obtaining opinions from outside counsel."