If you’re a business taxpayer with assets over $10 million and you file under FIN 48, the IRS has a new tax return schedule in the works for you.

IRS Commissioner Doug Shulman announced yesterday that the agency wants public and private companies that meet those criteria to provide “concise descriptions” of their uncertain tax positions and to disclose the maximum amount of income tax they’d be liable for if the positions were not sustained.

What, so FIN 48 itself wasn’t enough?

Apparently not. “Today, we spend up to 25 percent of our time in a large corporate audit searching for issues rather than having a straightforward discussion with the taxpayer about the issues,” Shulman complained in a speech to the New York State Bar Association announcing the initiative. “It would add efficiency to the process if we had access to more complete information earlier in the process regarding the nature and materiality of a taxpayer’s uncertain tax positions.”

That efficiency, of course, would come at the cost of yet another addition to the pile of corporate tax compliance obligations of the give-us-the-rope-to-hang-you-with variety.

Shulman was at pains to minimize the compliance impact, emphasizing that the proposal would not require taxpayers to disclose how weak or strong they consider their positions to be, or how much they’ve reserved on the books to cover the potential obligation.

And by “concise,” Shulman adds, he really does mean concise: “a few sentences that inform us of the nature of the issue, and not pages of factual description or legal analysis.”

But a glance at the proposed requirements as actually described in IRS Announcement 2010-9 shows that this is not something corporate tax departments will be able to churn out in 5 minutes. The “concise description” must include the rationale for each position, a description of the reasons for determining that it is indeed uncertain, and a specification of the amount of income tax due if the position is disallowed. And it must contain the following:

1. The Code sections potentially implicated by the position;

2. A description of the taxable year or years to which the position relates;

3. A statement that the position involves an item of income, gain, loss, deduction, or credit against tax;

4. A statement that the position involves a permanent inclusion or exclusion of any item, the timing of that item, or both;

5. A statement whether the position involves a determination of the value of any property or right; and

6. A statement whether the position involves a computation of basis.

The IRS is looking to move quickly on this, and is inviting comments on the proposal to be submitted by March 29. ###