Fin 48 Uncertainty And Transfer Pricing
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Fin 48 Uncertainty And Transfer Pricing
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Author : Susan C. Borkowski
language : en
Publisher:
Release Date : 2014
Fin 48 Uncertainty And Transfer Pricing written by Susan C. Borkowski and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with categories.
Financial Accounting Standards Board Interpretation No. 48: Accounting for Uncertainty in Income Taxes (hereafter, FIN48) has changed significantly how corporations must disclose uncertain tax positions. One uncertain tax position experienced by most TNCs is related to the cross-border shifting of income due to its transfer pricing transactions, its characterization of specific transactions as not affecting reportable income or as tax exempt, and its management decision that specific income is not taxable by a foreign tax authority (August 2008). The main areas of interest in this study are a TNC's disclosures of its uncertain tax positions both generally and specific to transfer pricing. These disclosures are assessed pre- and post-FIN 48 implementation in both a traditional statistical analysis and in a content analysis of the related footnotes to the annual reports for 2006 through 2009. DATA ANALYSIS IN PROCESS.
Accounting For Income Taxes
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Author : Christopher Desmond (Economist)
language : en
Publisher:
Release Date :
Accounting For Income Taxes written by Christopher Desmond (Economist) and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on with Corporations categories.
... provides an overview of the two-step process required under Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) 740-10 (formerly FASB Interpretation No. 48 (FIN 48)) and its application to transfer pricing. The Portfolio provides guidance on determining the units of account and identifying uncertain tax positions; recognizing uncertain tax positions; and evaluating the arm's-length nature of intercompany pricing. It further explains measurement analyses; disclosures; and the key stakeholders affected by ASC 740-10 in relation to transfer pricing.
Transfer Pricing And Corporate Taxation
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Author : Elizabeth King
language : en
Publisher: Springer Science & Business Media
Release Date : 2008-10-11
Transfer Pricing And Corporate Taxation written by Elizabeth King and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008-10-11 with Business & Economics categories.
National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.
Fin 48 Answer Book 2009 Edition
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Author : Mark L. Friedlich
language : en
Publisher: CCH
Release Date : 2008-08
Fin 48 Answer Book 2009 Edition written by Mark L. Friedlich and has been published by CCH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008-08 with Business & Economics categories.
FIN 48 Answer Book is designed to for practitioners who need quick and authoritative answers to questions concerning the implementation of FIN 48. This book uses simple straightforward language to provide guidance on consistent accounting practices and criteria for enterprises reporting tax benefits from uncertain tax positions. The question-and-answer format, with its breadth of coverage, effectively conveys the complex subject matter of implementing and applying FIN 48.
Differences Between Fin 48 And Ifric 23
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Author : Carolin Seibert
language : en
Publisher: Springer Nature
Release Date : 2022-08-31
Differences Between Fin 48 And Ifric 23 written by Carolin Seibert and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-08-31 with Business & Economics categories.
Uncertainties about the tax treatment of business transactions in the tax return or tax balance sheet can cause significant accounting challenges for current and deferred taxes in the financial statements. Whereas the accounting treatment of tax risks or tax audit risks has been regulated under US GAAP since 2006, a corresponding IFRS regulation was only published in 2017 and is effective from the 2019 fiscal year. The author takes this as an opportunity to analyze and critically assess the differences between the US GAAP accounting regulation “FIN 48 – Accounting for Uncertainty in Income Taxes” and the IFRS accounting regulation “IFRIC 23 – Uncertainty over Income Tax Treatments”. Building on the insights from her analysis, the author also examines the problem areas arising from IFRIC 23 from the perspective of the German tax authorities, German business practice and German advisory practice.
Lenzini Steel
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Author : Bradrick Cripe
language : en
Publisher:
Release Date : 2013
Lenzini Steel written by Bradrick Cripe and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with categories.
The Lenzini Steel case extends the classic cost/managerial accounting treatment of transfer pricing to include a wider range of inter-company transactions (ICTs): (1) product sales (traditional setting), (2) royalty payments for intellectual property, (3) machine acquisition and management fees, and (4) working capital loans. As described by Ernst & Young (2010), transfer pricing is one of the most important issues facing multinational companies today, and its relevance is increasing. Yet transfer pricing often remains essentially under-taught in junior, senior and masters-level accounting classrooms. Faculty need new teaching materials that reflect the increasing complexity associated with transfer pricing. We wrote the case to begin filling the void.In this case, students must integrate concepts from three accounting disciplines: cost/managerial accounting, financial reporting (through an auditor's view), and tax accounting. More importantly, however, students are asked to exercise their critical thinking skills by evaluating the four ITCs and establishing a defensible transfer pricing range for each. The Institute of Management Accountants (IMA 2013) and the American Institute of Certified Public Accountants (2005) have emphasized critical (or strategic) thinking skills as a key competency for accounting professionals. Based upon their analyses, students must use their critical thinking skills to assess the defense-ability of each ITC in terms of FIN 48 (codified as ASC 740-10), and recommend a reserve for uncertain tax positions that should be recorded in Lenzini's financial statements. The case requires students to travel from the more familiar (establishing a transfer price for different inter-company transactions) to the less familiar (predicting who benefits and who suffers from the student's transfer pricing decision), while considering an environment where division managers act in their own self-interest. As the final case requirement, students must develop the talking points they will use to convince company management to record the reserve and reduce net income, analyze which of the CFOs (1 corporate-level and 3 division-level) will push back, and anticipate the counter-arguments the CFOs might use.
Fin 48
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Author : David M. Sheehan
language : en
Publisher:
Release Date : 2006
Fin 48 written by David M. Sheehan and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2006 with Corporations categories.
"New FASB Interpretation 48 on Accounting for Uncertainty in Income Taxes ("FIN 48") will soon become effective, setting new thresholds for recognizing and measuring the benefits of a company's tax return positions in its financial statements."
Fin 48 And Tax Compliance
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Author : Lillian F. Mills
language : en
Publisher:
Release Date : 2011
Fin 48 And Tax Compliance written by Lillian F. Mills and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with categories.
We develop a model to examine the effects of Financial Accounting Standards Board (FASB) Interpretation No. 48, Accounting for Uncertainty in Income Taxes (FIN 48), on the strategic interaction between publicly-traded corporate taxpayers and the government. Several of our findings contradict conjectures voiced by members of the business community regarding the economic effects of implementing FIN 48. Specifically, taxpayers with strong facts obtain higher expected payoffs from uncertain tax benefits and some disclosed liabilities understate the expected tax liability. Consistent with the common conjectures, however, some taxpayers are more likely to be audited or are deterred from entering into transactions that generate uncertain benefits because of FIN 48.
Transfer Pricing
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Author : Kenneth J. Klassen
language : en
Publisher:
Release Date : 2018
Transfer Pricing written by Kenneth J. Klassen and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018 with categories.
Using a survey of tax executives from multinational corporations, we document that some firms set their transfer pricing strategy to minimize tax payments, but more firms focus on tax compliance. We estimate that a firm focusing on minimizing taxes has a GAAP effective tax rate that is 6.6 percentage points lower and generates about $43 million more in tax savings, on average, than a firm focusing on tax compliance. Available Compustat data on sample firms confirm our survey-based inferences. We also find that transfer pricing-related tax savings are greater when higher foreign income, tax haven use, and R&D activities are combined with a tax minimization strategy. Finally, compliance-focused firms report lower FIN 48 tax reserves than tax-minimizing firms, consistent with the former group using less uncertain transfer pricing arrangements. Collectively, our study provides direct evidence that multinational firms have differing internal priorities for transfer pricing, and that these differences are strongly related to the taxes reported by these firms.
Uncertainty In Transfer Pricing Tax Rules
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Author : Helen Rogers (Ph.D.)
language : en
Publisher:
Release Date : 2009
Uncertainty In Transfer Pricing Tax Rules written by Helen Rogers (Ph.D.) and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with categories.