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| Dick Adams wrote: - quote - > FASB Interpretation 48
Just when you think you've heard EVERYthing!> Accounting for Uncertainty in Income Taxes: > An interpretation of FASB Statement No. 109 > The AICPA just issued an update on FIN 48 with regards > to privately held companies. Hopefully someone more > familiar with FIN 48 will comment on this. > My interpretation of what I have read and discussed > discussed with a CPA in Tax practice is that FIN 48 > applies to complitations. In essence, it requires > privately held companies to accrue for potential tax > liabilities should they be audited! The best example > is travel and entertainment expenses which are a > immediate target when a company is being audited. > Thinking as an auditor, I would ask to see the company's > compilation reports for the year under audit and ask > how the accrual was calculated. About the only palatable > explanation is "My accountant put it there. You'll have > to ask her/him." But that just opens a bag of worms. > The CPA with whom I discussed this said that since a > compilation is already a disclaimer, he would rather > add a footnote for a Departure from GAAP for not > disclosing potential tax liabilities. > The AICPA indicated that applying FIN 48 to S-Corps > and Partnerships is under discussion. > On one hand, I am always opposed to tax fraud. On > the other hand, FIN 48 is requiring the taxpayer to > disclose their estimate of their tax deductions and > their tax postions being disallow upon audit. For a corporation who also uses a CPA to both prepare/audit financial statements and prepare tax returns. there shouldn't be a problem, right? After all, circular 230 trumps. ChEAr$, Harlan Lunsford, EA n LA -- << ------------------------------------------------------- > << The foregoing was not intended or written to be used, > << nor can it used, for the purpose of avoiding penalties > << that may be imposed upon the taxpayer. > << > << The Charter and the Guidelines for submitting posts > << to this newsgroup as well as our anti-spamming policy > << are at www.asktax.org. > << Copyright (2007) - All rights reserved. > << ------------------------------------------------------- > |
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| On Tue, 14 Oct 2008 01:27:50 EDT, rdadams[at]panix.com (Dick Adams) wrote: - quote - > FASB Interpretation 48
I think the most likely shortfall will result from companies> Accounting for Uncertainty in Income Taxes: > An interpretation of FASB Statement No. 109 > The AICPA just issued an update on FIN 48 with regards > to privately held companies. Hopefully someone more > familiar with FIN 48 will comment on this. > My interpretation of what I have read and discussed > discussed with a CPA in Tax practice is that FIN 48 > applies to complitations. In essence, it requires > privately held companies to accrue for potential tax > liabilities should they be audited! The best example > is travel and entertainment expenses which are a > immediate target when a company is being audited. not filing in all the appropriate jurisdictions and all appropriate taxes (use tax comes to mind). I would bet that most small businesses file in only the company's home state. Even though they have at least some out of state or out of the country activity. T&E shouldn't be an issue because if they have less than 1/3 chance it will upheld on audit then the preparer should be omitting the T&E from the return. I know that is a big assumption but the preparer shouldn't be putting stuff on the return that she/he knows will almost certainly be denied under audit. - quote - > Thinking as an auditor, I would ask to see the company's
I think IRS will eventually get around to asking for the> compilation reports for the year under audit and ask > how the accrual was calculated. About the only palatable > explanation is "My accountant put it there. You'll have > to ask her/him." But that just opens a bag of worms. accrual workpapers on small businesses, assuming the courts allow it. - quote - > The CPA with whom I discussed this said that since a
I think it will depend on how the third party users react to> compilation is already a disclaimer, he would rather > add a footnote for a Departure from GAAP for not > disclosing potential tax liabilities. the departure disclosure. I doubt many owners want to pay for a full analysis of the exposure. If the company has no out of state or out of the US obligations it is ignoring then it may not have anything to disclose. People who cheat should be dropped by CPAs as clients so for ethical CPAs I don't see poor/nonexistent documentation of T&E to be an issue. - quote - > The AICPA indicated that applying FIN 48 to S-Corps
--> and Partnerships is under discussion. > On one hand, I am always opposed to tax fraud. On > the other hand, FIN 48 is requiring the taxpayer to > disclose their estimate of their tax deductions and > their tax postions being disallow upon audit. > Dick Drew Edmundson, CPA Cary, NC -- << ------------------------------------------------------- > << The foregoing was not intended or written to be used, > << nor can it used, for the purpose of avoiding penalties > << that may be imposed upon the taxpayer. > << > << The Charter and the Guidelines for submitting posts > << to this newsgroup as well as our anti-spamming policy > << are at www.asktax.org. > << Copyright (2007) - All rights reserved. > << ------------------------------------------------------- > |
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| FASB Interpretation 48 Accounting for Uncertainty in Income Taxes: An interpretation of FASB Statement No. 109 The AICPA just issued an update on FIN 48 with regards to privately held companies. Hopefully someone more familiar with FIN 48 will comment on this. My interpretation of what I have read and discussed discussed with a CPA in Tax practice is that FIN 48 applies to complitations. In essence, it requires privately held companies to accrue for potential tax liabilities should they be audited! The best example is travel and entertainment expenses which are a immediate target when a company is being audited. Thinking as an auditor, I would ask to see the company's compilation reports for the year under audit and ask how the accrual was calculated. About the only palatable explanation is "My accountant put it there. You'll have to ask her/him." But that just opens a bag of worms. The CPA with whom I discussed this said that since a compilation is already a disclaimer, he would rather add a footnote for a Departure from GAAP for not disclosing potential tax liabilities. The AICPA indicated that applying FIN 48 to S-Corps and Partnerships is under discussion. On one hand, I am always opposed to tax fraud. On the other hand, FIN 48 is requiring the taxpayer to disclose their estimate of their tax deductions and their tax postions being disallow upon audit. Dick -- << ------------------------------------------------------- > << The foregoing was not intended or written to be used, > << nor can it used, for the purpose of avoiding penalties > << that may be imposed upon the taxpayer. > << > << The Charter and the Guidelines for submitting posts > << to this newsgroup as well as our anti-spamming policy > << are at www.asktax.org. > << Copyright (2007) - All rights reserved. > << ------------------------------------------------------- > |