The IRS on 23 March released guidance in the form of answers to several frequently asked questions (FAQs) raised by taxpayers and practitioners with respect to reporting “uncertain tax positions” on the fi nal Schedule UTP and earlier guidance, which the IRS had issued in September 2010. The new guidance addresses the following UTP FAQs: defi nition of “suffi ciently certain,” interim fi nancial statement changes to reserves, transition rules, and the impact of interest and penalties. With respect to the policy of restraint, the FAQ confi rm that the policy of restraint applies not only to examinations, but also to the Appeals process and Tax Court litigation. Changes to the policy of restraint apply to any request for documents outstanding on or made after 24 September 2010 in any open examination.