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Prepare for the Unknown

Rosemary Blundell National Tax Director and Colin Copeland Tax Director at Mazars LLP examine FIN 48 and what it means for US-parented groups
It is not very often that an accounting development creates a storm amongst tax practitioners but that is exactly that happened in the US when the Financial Accounting Standards Board (FASB) issued Interpretation No 48 (FIN 48). FIN 48 significantly changes the way companies reporting under US GAAP account for and disclose uncertain income tax positions. The cause for alarm in the tax community arose due to fears that the level of disclosures required would highlight the tax issues companies were most uncertain about and effectively create a list of items for tax authorities to enquire into. Typical areas of uncertainty include transfer pricing permanent establishment exposure and anti-tax-haven...

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