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Q&A Forum

Under US GAAP, is there a requirement to consider the analysis of uncertain tax positions (formerly FIN48) when preparing interim financial


Topic Expert
Nathan Curtis
Title: CPA
(CPA, ) |

The short answer is yes, FIN 48 must be applied to interim periods after the effective date. For public companies, they're doing this on a quarterly basis and have been for several years. Most private companies will only go through the FIN 48 analysis at the end of the year in connection with their annual audit or review. If a priate company has audited or reviewed interim financial statements, they would also need to go through the analysis on a quarterly basis, or have a modified report explaining the GAAP departure. For interim financial statements prepared by the client that are used by management, the board, or that are given to bankers or other stakholders, but that are NOT audited or reviewed, most private companies will not go through the analysis quarterly, and instead just note on the face of the financials that certain adjustments required by GAAP are not applied on a quarterly basis. Other examples of adjustments many private companies will only do on an annual basis include option/warrant comp expense, some reserves and accruals, pension liability costs and also the tax provision required by what was formerly FAS 109.

Topic Expert
Barrett Peterson
Title: Senior Manager, Actg Stnds & Analysis
Company: TTX
(Senior Manager, Actg Stnds & Analysis, TTX) |

Evaluation is required for any reporting for external parties' use. For internal management reporting, GAAP is not even required so reporting should focus on important uncertain tax position issues if important.


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