some corporations with assets of at least $10 million (it had been $50 million which is why your editor was unaware) effective with 2014 tax years. UTP is shorthand for Uncertain Tax Position, and a filing requirement is triggered for a tax position taken on its federal income tax return if either:
a. The corporation or a related party has recorded a reserve with regard to that tax position for U.S. federal income tax in audited financial statements; or,
b. The corporation or a related party did not record a reserve for the tax position because the corporation expects to litigate the position.
While most of us are not involved with corporations which use audited financial statements as a basis for income tax filings, we may know someone who does and can pass the word regarding the lowered asset threshold.