We find over 31 percent of U.S. firms report a zero ending balance for their unrecognized tax benefits (UTBs). We refer to these firms as zero UTB firms and explore explanations for their prevalence. We find zero UTB firms are less complex than positive UTB firms. Specifically, they are smaller, less profitable, have less R&D and foreign earnings, and fewer operating segments and XBRL tags. We also find some evidence that these firms have less efficient tax departments. When splitting zero UTB firms by tax haven activity, we find that those with haven operations are more aggressive in their financial reporting than haven firms with positive UTBs. We also find that zero UTB firms both with and without tax haven operations are subject to less IRS scrutiny than positive UTB firms. Overall, although zero UTB firms are generally less complex, our results suggest that a subset may warrant further scrutiny.

JEL Classifications: H25; H26; H32; M41; M48.

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