Fin 48 and tax risk management

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"We experienced what might be characterised as FIN 48-lite in its first year of operation but the full impact is being felt now and it is a major problem for US companies and foreign multinationals listed in the States," says one Washington, DC tax lawyer.

...The FASB has said the interpretation should result in increased relevance and comparability in financial reporting of income taxes because uncertain tax positions accounted for in accordance with statement 109 will be evaluated for recognition, derecognition, and measurement using consistent criteria.

...In the first step, recognition, an enterprise determines whether it is more-likely-than-not (MLTN) that a tax position will be sustained upon examination, including resolution of any related appeals or litigation processes, based on the technical merits of the position.

Posted by Daniel N Erasmus www.dnerasmus.com daniel@dnerasmus.com

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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