In June, 2006 the Financial Accounting Standards Board issued Interpretation 48 of Financial Accounting Standard 109. This interpretation, known as ¡°FIN 48¡±, is intended to eliminate inconsistency in accounting for uncertain tax positions in financial statements certified in accordance with U.S. GAAP. FIN 48 mandates new rules for recognition, de-recognition, measurement, and disclosure of all tax positions.
FIN 48 Policy and Field Guidance
IRS has determined that documents produced by a taxpayer and/or its auditors to substantiate the taxpayer¡¯s uncertain tax positions in compliance with FIN 48 are included within the Service¡¯s interpretation of Tax Accrual Workpapers and are therefore subject to the applicable policy of restraint.
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FIN 48 and Tax Accrual Workpaper (TAW) Policy Update ¨C LMSB Commissioner Memorandum dated May 10, 2007.
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¨C Chief Counsel Memorandum dated March 22, 2007.
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LMSB Field Examiner¡¯s Guide ¨C FIN 48 Implications (May 2007)
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IRM 4.10.20 - Requesting Audit, Tax Accrual, or Tax Reconciliation Workpapers