FASB Interpretation No 48FASB解释没有48.pptVIP

FASB Interpretation No. 48 An Interpretation of FASB Statement No. 109 Royce W. Mitchell Purpose and Objectives Reasons for issuance The scope of the interpretation The Two-Step process Recognition and the “more-likely-than-not” benchmark Measurement of benefit to be recognized Disclosure requirements Effective date and transition Reasons for Issuance Statement 109 contains no specific guidance on uncertainty Significant diversity in practice “Lowest common denominator” accounting Scope All tax positions accounted for under Statement 109 Applies to past returns filed and future returns to be filed Federal and state income tax positions Interim and annual periods Two-Step Process Recognition “More-likely-than-not” standard Likelihood of more than 50 percent that the tax position will be upheld upon examination Requires positive assertion by Company Considers facts, circumstances and information available at reporting date Presumes examination and consideration of precedents Each position examined on its on – no offsets Determination of “unit-of-measure” Two-Step Process Measurement Largest amount of tax benefit that meets the more-likely-than-not standard Considers amounts and probabilities of outcomes that could be realized Measurement done within unit of measure for each tax position Measurement Example Other Consideration Tax planning strategies Subsequent changes in circumstance MLTN threshold met Tax matter settled Statute of limitations passed Changes in Judgment Result of evaluation of new information Not from new evaluation or new interpretation by management Discreet item in period change occurs Interest and Penalties Start accruing interest in first period required by relevant tax law Penalties accrued if position does not meet minimum statutory requirement Classification Liability associated with aggressive tax position not deferred tax liability Classified as current or long-term like any other liability Accounting policy elections- Interest cl