FIN 48 compliance: disclosing tax positions in an age of uncertainty.

Tax Adviser, The, January, 2008 by Everett, John O.; Hennig, Cherie J.; Raabe, William A.

EXECUTIVE SUMMARY

* The interaction of FAS 109 and FIN 48 will result in greater public disclosure of tax planning techniques.

* Under FIN 48, a tax position is recorded only if the tax position is more likely than not to be sustained on examination (including related appeals or litigation processes).

* A material tax position is tested under a two-step process consisting of a recognition step and a measurement step.

* FIN 48 requires a reevaluation of all tax positions at the end of each reporting period. Prior recognized positions may be derecognized or remeasured, and prior positions may be recognized in each reevaluation.

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FIN 48 changes the way that much of the tax profession carries out its...

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