IRS Issues FIN 48 Field Guide


The IRS Large and Mid-Size Business Division analyzed implications of FASB Interpretation no. 48, Accounting for Uncertainty in Income Taxes, in an industry directive and field examination guide. The summary and 10 questions and answers of LMSB-04-0507-045 cover some questions extensively discussed elsewhere, such as FIN 48 workpapers falling within the Service’s policy of restraint in requesting workpapers generally. Other questions treat more obscure points, such as whether a restricted consent agreement can be used to extend the statute of limitations for uncertain tax positions. (The guide says it depends on the facts and circumstances and lists five possible determining factors.) The guide also covers closing agreements, methods for expediting a taxpayer desire for resolution of uncertain items and whether a FIN 48-related public disclosure might prompt the Service to reopen a closed examination cycle.

SPONSORED WHITE PAPER

Preparing the statement of cash flows

This instructive white paper outlines common pitfalls in the preparation of the statement of cash flows, resources to minimize these risks, and four critical skills your staff will need as you approach necessary changes to the process.

RESOURCES

Keeping you informed and prepared amid the coronavirus crisis

We’re gathering the latest news stories along with relevant columns, tips, podcasts, and videos on this page, along with curated items from our archives to help with uncertainty and disruption.