The Financial Accounting Standards Board (FASB) issued Interpretation No. 48, Accounting for Uncertainty in Income Taxes- an interpretation of FASB Statement No. 109 (FIN 48). FIN 48 clarifies the accounting for uncertainty in income taxes recognized in an enterprise’s financial statements in accordance with FASB Statement No. 109, Accounting for Income Taxes (SFAS 109). This Interpretation prescribes a recognition threshold and measurement attribute for the financial statement recognition and measurement of a tax position taken or expected to be taken in a tax return. This Interpretation also provides guidance on derecognition, classification, interest and penalties, accounting in interim periods, disclosure, and transition. FIN 48 is effective for fiscal years beginning after December 15, 2006.

Section I. FASB

NOTE: To comply with FASB copyright provisions, members are required to access FASB publications through www.fasb.org/st.  The FASB guidance listed below is available under "View FASB Pronouncements" section of the Web page provided above.   

FASB Interpretation

• FIN 48, Accounting for Uncertainty in Income Taxes - an interpretation of FASB Statement No. 109 (Issued June 2006)

FASB Standard

• SFAS 109, Accounting for Income Taxes – (Issued February 1992)

FASB Staff Positions (FSP)

• FSP FIN 48-3 - Effective Date of FASB Interpretation No. 48 for Certain Nonpublic Enterprises - FIN 48 Deferral for Certain Nonpublic Entities (Issued December 30, 2008)

• FSP FIN 48-2 - Effective Date of FASB Interpretation No. 48 for Certain Nonpublic Enterprises - FIN 48 Deferral for Certain Nonpublic Entities (Issued February 1, 2008)

• FSP FIN 48-1 - Definition of Settlement in FASB Interpretation No. 48 - (Issued May 2, 2007)

Section II. SEC

SEC Regulations Committee

• Disclosure of FIN 48 Liabilities in the Contractual Obligations Table (Discussion Document E from the April 17, 2007 joint meeting of the SEC Regulations Committee and SEC Staff)

• Determining the Amount of Interest on FIN 48 Liabilities to be Included in Fixed Charges for Purposes of Calculating the Ratio of Earnings to Fixed Charges (Discussion Document F from the April 17, 2007 joint meeting of the SEC Regulations Committee and SEC Staff)

• View the FIN 48 Implementation Discussion Document Issued by CAQ SEC Regulations Committee – Revised as of February 6, 2007 (Appendix A from the September 26, 2006 SEC Regulations Committee joint meeting with the SEC staff)

Other SEC Resources

• June 28, 2007 Letter to Fidelity Investments, Massachusetts Financial Services Company and OppenheimerFunds, Inc. re: Implementation of FASB Interpretation No. 48 (SEC Division of Investment Management)

• The Economics of FIN 48: Accounting for Uncertainty in Income Taxes, Speech by Chester S. Spatt, SEC Chief Economist (March 2007)

Section III. Other FIN 48 Resources

Learn More about FIN 48

• IRS To Help GAAP Basis Taxpayers Clean Up Tax Accruals as FIN 48 Disclosures Loom – The AICPA Tax Center, which provides guidance, information, and practice tools to the tax practitioner, has issued this Tax Section E-Alert in order to alert member of the IRS offer of help with FIN 48 compliance. This alert provides a direct link to the IRS guidance and direction.