[Past Issues] [TOC]

Uncertain Tax Positions: An Update of Reporting Requirements Since 2008

Ian J. Redpath, Thomas J. Vogel and George F. Kermis

The BRC Academy Journal of Business

Volume 3

Number 1

Print ISSN: 2152-8721 Online ISSN: 2152-873X

Date: March 15, 2013

First Page 97

Last Page 119

Abstract

From 2006 to 2008, the accounting profession experienced substantial changes in the reporting of uncertain tax positions and potential preparer penalties resulting from these positions. Prior research provides an extensive review of the changes from FIN 48, IRC Penalty Disclosure, and Circular 230. Over the past few years, the reporting rules have been further studied, and in some cases, modified. From a financial reporting perspective, the Financial Accounting Foundation used the controversial disclosure requirements of FIN 48 to conduct its first “Post-Implementation Review” of an accounting standard. In its report, the FAF concludes that FIN 48 provided relevant information to the users of financial statements. From a taxation perspective, the IRS revised its penalty provisions and developed a self-reporting requirement that forces certain taxpayers with a FIN 48 position to disclose the position to the IRS when fi ling tax returns. In this paper we summarize these recent developments, and discuss how the accounting profession will be impacted in subsequent years.

Download Paper