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.
FIN 48 and Tax Accrual Workpaper (TAW) Policy Update – LMSB Commissioner Memorandum dated May 10, 2007.
FIN 48 Tax Accrual Workpapers – Chief Counsel Memorandum dated March 22, 2007.
LMSB Field Examiner’s Guide – FIN 48 Implications (May 2007)
IRM 4.10.20 - Requesting Audit, Tax Accrual, or Tax Reconciliation Workpapers
Prior LMSB Initiative to Address Certain Implications of FIN 48
LMSB conducted an initiative to assist taxpayers in resolving uncertain issues on an expedited basis prior to the effective date of FIN 48. The expedited procedures were effective through March 31, 2007.