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Much Uncertainty About Uncertain Tax Positions

Much Uncertainty About Uncertain Tax Positions
Author: Robert Probasco
Publisher:
Total Pages: 10
Release: 2017
Genre:
ISBN:

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The Internal Revenue Service (IRS) announced in January 2010 a new initiative to require certain businesses to report “uncertain tax positions” on a new schedule filed with their annual tax returns. Draft schedules and instructions issued in April 2010 clarified some of the mechanical aspects of the new requirement but left many open issues and questions. The IRS proposal built on requirements by the Financial Accounting Standards Board (FASB) in FASB Interpretation No. 48, Accounting for Uncertainty in Income Taxes (“FIN 48”). The standard requires companies, in their financial statements, to reserve some of the benefits from any position taken on their tax returns unless it is more likely than not that the IRS would fully concede the issue prior to litigation if it arose during an audit.The article describes the proposals and then discusses concerns and open issues. The most significant concerns include that, as a practical matter, information asymmetry may result in overly aggressive positions taken by the IRS and the IRS may not have the administrative capacity to use the additional information properly. The proposal also raises concerns about privilege and waiver, particularly with respect to the work-product doctrine and tax accrual workpapers.


Accounting for Income Taxes

Accounting for Income Taxes
Author: Amy Dunbar
Publisher:
Total Pages: 0
Release: 2008
Genre: Accounting
ISBN:

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... provides a comprehensive analysis of FASB interpretation no. 48, Accounting for uncertainty in income tax position--an interpretation of FASB statement no. 109, which addresses the accounting for uncertainty in income taxes recognized in a company's financial statements in accordance with FASB statement no. 109, Accounting for income taxes.


Accounting for Income Taxes

Accounting for Income Taxes
Author: Amy Dunbar
Publisher:
Total Pages:
Release: 2008
Genre: Income tax
ISBN:

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...Analyzes issues that arise due to FASB interpretation no. 48, Accounting for uncertainty in income tax positions--an interpretation of FASB statement no. 109, which addresses the accounting for uncertainty in income taxes recognized in a company's financial statements in accordance with FASB statement no. 109, Accounting for Income Taxes.


The Benefits of Uncertainty

The Benefits of Uncertainty
Author: Trent Krupa
Publisher:
Total Pages: 0
Release: 2023
Genre:
ISBN:

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Economic theory suggests that tax-favored strategies attract investment, and this increased investment demand offsets tax benefits through lower pre-tax returns (i.e., implicit taxes). We propose that aggressive strategies that generate uncertain tax benefits have lower demand due to both the concern that the tax authority will overturn these uncertain strategies upon audit and because the firm does not receive the full benefit of the strategies on its financial statements. Consistent with this, we find that firms' investment in uncertain tax positions, holding cash effective tax rates constant, is associated with lower implicit taxes (i.e., higher pre-tax earnings and firm value). Subsequent analysis using exogenous variation in IRS enforcement supports the audit mechanism and helps mitigate concerns about reverse causality. Lower implicit taxes also arise, in part, from the earnings effects of uncertain tax positions, supporting the financial reporting mechanism. Our results illustrate a non-tax benefit of uncertain tax strategies.


How Do Disclosures of Tax Uncertainty to Tax Authorities Affect Reporting Decisions?

How Do Disclosures of Tax Uncertainty to Tax Authorities Affect Reporting Decisions?
Author: Erin Marie Towery
Publisher:
Total Pages: 150
Release: 2013
Genre:
ISBN:

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This study exploits the recently-issued Uncertain Tax Position Statement (Schedule UTP) to examine the effect of mandatory disclosures of tax uncertainty to tax authorities on firms' reporting decisions. Schedule UTP requires firms to disclose federal income tax positions to the Internal Revenue Service that have been classified as 'uncertain' for financial reporting purposes. In showing how Schedule UTP disclosure requirements affect private and public reporting decisions, I provide insights into the usefulness of these disclosures. Using confidential tax return data and public financial statement data, I find that after imposition of Schedule UTP reporting requirements, firms report lower financial reporting reserves for uncertain income tax positions, but do not claim fewer income tax benefits on their federal tax returns. These findings suggest some firms changed their financial reporting for uncertain tax positions to avoid Schedule UTP reporting requirements without changing the underlying positions. The effect is concentrated among firms with greater business complexity, whose business operations facilitate tax planning strategies that are more difficult for the IRS to identify. More broadly, my results imply private disclosures of tax uncertainty can affect the informativeness of public disclosures of tax uncertainty.


FIN 48, Uncertainty and Transfer Pricing

FIN 48, Uncertainty and Transfer Pricing
Author: Susan C. Borkowski
Publisher:
Total Pages: 0
Release: 2014
Genre:
ISBN:

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Financial Accounting Standards Board Interpretation No. 48: Accounting for Uncertainty in Income Taxes (hereafter, FIN48) has changed significantly how corporations must disclose uncertain tax positions. One uncertain tax position experienced by most TNCs is related to the cross-border shifting of income due to its transfer pricing transactions, its characterization of specific transactions as not affecting reportable income or as tax exempt, and its management decision that specific income is not taxable by a foreign tax authority (August 2008). The main areas of interest in this study are a TNC's disclosures of its uncertain tax positions both generally and specific to transfer pricing. These disclosures are assessed pre- and post-FIN 48 implementation in both a traditional statistical analysis and in a content analysis of the related footnotes to the annual reports for 2006 through 2009. DATA ANALYSIS IN PROCESS.


Distilling the Reserve for Uncertain Tax Positions

Distilling the Reserve for Uncertain Tax Positions
Author: John R. Robinson
Publisher:
Total Pages: 0
Release: 2013
Genre:
ISBN:

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We examine the extent to which the reserve for unrecognized tax benefits consistently reflects uncertain tax avoidance. We analyze the financial statement disclosures for 19 paper companies that received a total of $6.4 billion in direct government subsidies structured as refundable excise taxes during 2009. Each of these companies included the refunds in financial income, but 14 of these firms excluded all or part of the refunds from taxable income. Despite the unprecedented nature of the exclusion, we find significant variation in the tax accruals meant to represent uncertain tax positions. Our evidence suggests that additions to the reserve for uncertain tax benefits are an inconsistent empirical measure of uncertain tax avoidance because of the wide latitude allowed managers in making judgments about tax uncertainties. Moreover, we find some evidence that these judgments are related to characteristics generally associated with weak corporate governance.


Risk, Uncertainty and Profit

Risk, Uncertainty and Profit
Author: Frank H. Knight
Publisher: Cosimo, Inc.
Total Pages: 401
Release: 2006-11-01
Genre: Business & Economics
ISBN: 1602060053

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A timeless classic of economic theory that remains fascinating and pertinent today, this is Frank Knight's famous explanation of why perfect competition cannot eliminate profits, the important differences between "risk" and "uncertainty," and the vital role of the entrepreneur in profitmaking. Based on Knight's PhD dissertation, this 1921 work, balancing theory with fact to come to stunning insights, is a distinct pleasure to read. FRANK H. KNIGHT (1885-1972) is considered by some the greatest American scholar of economics of the 20th century. An economics professor at the University of Chicago from 1927 until 1955, he was one of the founders of the Chicago school of economics, which influenced Milton Friedman and George Stigler.


Investment under Uncertainty

Investment under Uncertainty
Author: Robert K. Dixit
Publisher: Princeton University Press
Total Pages: 484
Release: 2012-07-14
Genre: Business & Economics
ISBN: 1400830176

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How should firms decide whether and when to invest in new capital equipment, additions to their workforce, or the development of new products? Why have traditional economic models of investment failed to explain the behavior of investment spending in the United States and other countries? In this book, Avinash Dixit and Robert Pindyck provide the first detailed exposition of a new theoretical approach to the capital investment decisions of firms, stressing the irreversibility of most investment decisions, and the ongoing uncertainty of the economic environment in which these decisions are made. In so doing, they answer important questions about investment decisions and the behavior of investment spending. This new approach to investment recognizes the option value of waiting for better (but never complete) information. It exploits an analogy with the theory of options in financial markets, which permits a much richer dynamic framework than was possible with the traditional theory of investment. The authors present the new theory in a clear and systematic way, and consolidate, synthesize, and extend the various strands of research that have come out of the theory. Their book shows the importance of the theory for understanding investment behavior of firms; develops the implications of this theory for industry dynamics and for government policy concerning investment; and shows how the theory can be applied to specific industries and to a wide variety of business problems.