Jeffrey A. Friedman, Partner Michele Borens, Partner Leah Robinson, Partner TEI/IPT SALT Day December 9, 2014
|
|
- Judith Rogers
- 7 years ago
- Views:
Transcription
1 Jeffrey A. Friedman, Partner Michele Borens, Partner Leah Robinson, Partner TEI/IPT SALT Day December 9, 2014 Reserves Release or Forever?
2 Agenda Overview of issues and concerns with reserves FIN 48 Standards FAS 5 Standards Disclosures Brief discussion regarding required disclosures 2
3 Background In principle, the validity of a tax position is a matter of tax law. It is not controversial to recognize the benefit of a tax position in an enterprise s financial statements when the degree of confidence is high that the tax position will be sustained upon examination by a taxing authority. However, in some cases, the law is subject to varied interpretation, and whether a tax position will ultimately be sustained may be uncertain. FASB Interpretation No. 48 (pg. 4). For these uncertain tax positions, under FAS 5 or FIN 48, a taxpayer may be required to book a reserve. 3
4 Reserves Are they forever? Financial accounting standards require companies to book financial statement reserves for certain tax positions The reserve standard is different for income taxes and other non-income taxes FIN 48 FAS 5 Once a reserve is booked, there must be an event (the standard must no longer be met) that occurs before the reserve can be released 4
5 Background However, at what point in time can the taxpayer release the reserve? What if a taxing authority never directly challenges the taxpayer on the uncertain tax position will the taxpayer ever be able to release the reserve? What can taxpayers do to help trigger an event to release the reserve? 5
6 FIN 48 6
7 FIN 48 FIN 48 was renamed ASC 740 FASB Accounting Standards Codification project became effective September 15, 2009 Project didn t change anything substantively Project reorganized existing pronouncements and statements New reference for FIN 48 is ASC However, many practitioners continue to refer to as FIN 48 7
8 FIN 48 Statement 109, published in 1992, led to inconsistencies around what standard accounting firms were requiring to account for income tax loss contingencies. Statement 109 contains no specific guidance on how to address uncertainty in accounting for income tax assets and liabilities. As a result, diverse accounting practices have developed resulting in inconsistency in the criteria used to recognized, derecognize, and measure benefits related to income taxes. The diversity in practice has resulted in noncomparability in reporting income tax assets and liabilities. FASB Interpretation No. 48 (pg. 4). 8
9 FIN 48 Effective for fiscal years after December 15, 2006 Used to account for income tax loss contingencies Not applicable to taxes based on gross receipts except for TX and MI (Single Business Tax) Adopted more likely than not standard An enterprise shall initially recognize the financial statement effects of a tax position when it is more likely than not, based on the technical merits, that the position will be sustained upon examination. ASC More likely than not means a likelihood of more than 50% Examination includes resolution of related appeals or litigation processes Includes consideration of all facts, circumstances, and information available at the reporting date 9
10 FIN 48 A tax position is [a] position in a previously filed tax return or a position expected to be taken in a future tax return that is reflected in measuring current or deferred income tax assets and liabilities for interim or annual periods. ASC The concept of a tax position is broad and includes, but is not limited to: A decision not to file a return; An allocation or shift of income between jurisdictions; The characterization of income or a decision to exclude reporting taxable income in a tax return; A decision to classify a transaction, entity, or other position in a tax return as tax exempt; or An entity s status, including its status as a pass-through entity or a tax exempt not-for profit entity. 10
11 FIN 48 If the tax benefit is determined to meet the more likely than not standard, the benefit shall be measured as the largest amount that has a greater than 50% likelihood of being realized upon settlement. If the more likely than not standard is not met in the period for which the tax position is taken or expected to be taken, the company shall recognize the benefit of the tax position in the first interim period in which one of the following conditions is met: The more likely than not recognition threshold is met by the reporting date. The tax position is effectively settled through examination, negotiation, or litigation. The statute of limitations for the relevant taxing authority to examine and challenge the tax position has expired. 11
12 FIN 48 Example Company has been filing income tax returns in State A in However, before 2005, it is not sure when it first had nexus with or was doing business in State A. Because no tax returns were filed before 2005, the statute of limitations for those years never began running. State A has provided no guidance on how far back it will look in determining if there is a tax return due and if a tax deficiency is owed. How long must State A continue to book a reserve for? 12
13 FIN 48 This example highlights the dilemma for taxpayers Once the reserve gets booked, can the taxpayer ever release it? This issues comes up most frequently with respect to nexus Taxpayers and taxing authorities often have widely disparate ideas regarding what establishes nexus with a state such that the state can impose its income tax on the taxpayer This problem has only been exacerbated in recent years by the development of economic nexus, affiliate nexus, factor nexus, etc. 13
14 FIN 48 What if a state has a published look-back period? Does the taxpayer need to accrue a reserve for only the look-back period or book a reserve for years beyond the state s published look-back period? Other possible solutions? Could participation in a state s voluntary disclosure program allow the taxpayer to release the reserve? Could taxpayer seek guidance from the taxing authority on its position? Letter ruling? Binding or non-binding Legislative change? Regulations? 14
15 FIN 48 Other possible solutions? Informal guidance regarding state s look back policy Documented conversation with state Another similar case that strengthens position Registration with the state and expiration of the SOL for periods after registration Audit 15
16 FAS 5 16
17 FAS 5 FAS 5 was renamed ASC 450 New reference for FAS 5 is ASC 450 However, many practitioners continue to refer to as FAS 5 FAS 5 is applicable to non-income taxes, including: employment taxes, sales and use taxes, abandoned and unclaimed property, property taxes, franchise/net worth taxes, and gross receipts taxes. 17
18 FAS 5 FAS 5 requires companies to accrue a reserve for a loss contingency if both of the following conditions are met: It is probable that an asset had been impaired or a liability had been incurred at the date of the financial statement. This amount of the liability is reasonably estimable. Probable is defined as the future events are likely to occur. If no accrual is made for a loss contingency because one or both of the conditions are not met, disclosure of the contingency shall be made when there is at least a reasonable possibility that a loss or an additional loss may have been incurred. 18
19 FAS 5 Example Company claimed a credit against its gross receipts taxes in State A. However, it is unclear whether the conditions required to be met to claim the credit were in fact met before the deadline to claim the credit. If Company determines that it is not probable that a loss will occur upon audit, then No loss contingency reserve would have to be accrued Financial statement benefit of the deduction is fully recognized 19
20 FAS 5 Possible solutions? Could participation in a state s voluntary disclosure program allow the taxpayer to release the reserve? Could taxpayer seek guidance from the taxing authority on its position? Letter ruling? Binding or non-binding Legislative change? Regulations? 20
21 FAS 5 Possible solutions? Informal guidance regarding state s look back policy Documented conversation with state Another similar case that strengthens position Registration with the state and expiration of the SOL for periods after registration Audit 21
22 California Sales and Use Tax Statute of Limitations California law provides a statute of limitations for issuing a deficiency determination against non-filers for sales/use taxes: In the case of failure to make a return, every notice of determination shall be mailed within eight years after the last day of the calendar month following the quarterly period for which the amount is proposed to be determined. Cal. Rev. & Tax Code Sec. 6487(a). For FAS 5 purposes, taxpayer could release a reserve after 8 years because California would not be able to assess it Cf. California does not have a similar statute of limitations for non-filers for corporate income taxes. Cal. Rev. & Tax Code Sec (a). For FIN 48 purposes, taxpayer would never be able to release a reserve for an income tax liability if no return was filed. 22
23 New York Tax Collections Statutes of Limitations New York The statute of limitations to collect tax liabilities that have been assessed and for which a notice and demand has been issued is 20 years from the first date a warrant could be filed by the Department of Taxation and Finance. N.Y. Tax Law 174-b(1). The first date a warrant could be filed is defined as: If there is no right to a hearing first date a warrant could be filed is the day after the last day specified for payment of the notice and demand issued for the tax liability If there is a right to a hearing the first date a warrant could be filed is the day after the opportunity to apply for a hearing or review has been exhausted 23
24 Missouri Sales and Use Tax Statutes of Limitation Missouri can assess sales and use tax at any time in the case of a fraudulent return or neglect or refusal to make a return Mo. Rev. Stat. Sec (1). What is neglect or refusal to make a return? If taxpayer has reasonable position that it is not required to collect and remit sales and use tax under Missouri law, may only be subject to 3 year statute of limitation. In other cases, every notice of additional amount proposed to be assessed under this chapter shall be mailed to the person within 3 years after the return was filed or required to be filed. Mo. Rev. Stat. Sec (3). 24
25 Questions? Jeffrey A. Friedman Michele Borens Leah Robinson
26 Connect with us! The Sutherland SALT Shaker mobile app is now available. Download today from the: Windows Phone Store itunes App Store Google Play Amazon Appstore for Android Visit us at Sutherland SALT Group 26
ORIGINAL PRONOUNCEMENTS
Financial Accounting Standards Board ORIGINAL PRONOUNCEMENTS AS AMENDED FASB Interpretation No. 48 Accounting for Uncertainty in Income Taxes an interpretation of FASB Statement No. 109 Copyright 2010
More informationNew Technologies How to Classify/Determine Nexus and Other Issues
Tax Executives Institute Region VIII Conference Santa Barbara June 15, 2015 Jeff Friedman Michele Borens New Technologies How to Classify/Determine Nexus and Other Issues Agenda Background on Nexus What
More informationSAN JOSE DOWNTOWN PROPERTY OWNERS' ASSOCIATION (A California Nonprofit Mutual Benefit Corporation) *** FINANCIAL STATEMENTS Year Ended June 30, 2010
SAN JOSE DOWNTOWN PROPERTY OWNERS' ASSOCIATION *** FINANCIAL STATEMENTS Year Ended June 30, 2010 TABLE OF CONTENTS Pages ACCOUNTANT'S REVIEW REPORT 1 FINANCIAL STATEMENTS: Statement of Financial Position
More informationCoordinating State and Federal Income Tax Audits
Leah Robinson, Partner Scott Wright, Partner May 21, 2015 Coordinating State and Federal Income Tax Audits 1 State Tax Exam Issues Coordinating Disclosure of Information to IRS and State Tax Authorities
More informationFinancial Accounting Series
Financial Accounting Series NO. 281-B JUNE 2006 FASB Interpretation No. 48 Accounting for Uncertainty in Income Taxes an interpretation of FASB Statement No. 109 Financial Accounting Standards Board of
More informationSeptember 2011. Tax accounting services: The impact of transfer pricing in financial reporting
September 2011 Tax accounting services: The impact of transfer pricing in financial reporting This publication serves to highlight several important areas of financial reporting that can be affected by
More informationLeah Robinson (212) 389-5043. In a New York Minute: Tax Reform Developments
Leah Robinson (212) 389-5043 In a New York Minute: Tax Reform Developments 1 Nexus Combination Tax Base Apportionment NOLs Credits and Incentives Other Leadership Changes What s on the Horizon 2 Nexus
More informationUncertainty in Income Taxes. A Roadmap to Applying Interpretation 48
Uncertainty in Income Taxes A Roadmap to Applying Interpretation 48 Section indicator Descriptor Deloitte Uncertainty in Income Taxes A Roadmap to Applying Interpretation 48 FASB Interpretation No. 48,
More informationSample Disclosures Accounting for Income Taxes. February 2015
Sample Disclosures Accounting for Income Taxes February 2015 Contents Use of These Sample Disclosures 1 Management s Discussion and Analysis General 2 MD&A Results of Operations 2 MD&A Critical Accounting
More informationIncome Tax Accounting under IFRS: A look ahead*
IFRS Income Tax Accounting Income Tax Accounting under IFRS: A look ahead* Accounting for uncertain tax positions About this series The IASB has proposed significantly changing the current IFRS standard
More informationStock based compensation guidance to increase income statement volatility (see update note below)
Stock based compensation guidance to increase income statement volatility (see update note below) No. US2016 03 April 19, 2016 (Revised April 25, 2016) What s inside: Background. 1 Key provisions 2 Income
More informationLifting the fog* Accounting for uncertainty in income taxes
Lifting the fog* Accounting for uncertainty in income taxes Contents Introduction 01 Identifying uncertain tax positions 02 Recognizing uncertain tax positions 03 Measuring the tax benefit 04 Disclosures
More informationSAN FRANCISCO AMENDS BUSINESS TAX ORDINANCE BOARD OF REVIEW ELIMINATED, STATUTE OF LIMITATIONS FOR REFUNDS INCREASED AND MUCH MORE. Tax March 26, 2004
SAN FRANCISCO AMENDS BUSINESS TAX ORDINANCE BOARD OF REVIEW ELIMINATED, STATUTE OF LIMITATIONS FOR REFUNDS INCREASED AND MUCH MORE Tax On February 19, 2004, San Francisco Mayor Gavin Newsom approved recent
More informationFederal Change Reporting: Hot Topics & Current Issues
Houston Tax Executives Institute May 7, 2013 Federal Change Reporting: Hot Topics & Current Issues Jordan M. Goodman (312) 606-3225 jgoodman@saltlawyers.com Marilyn A. Wethekam (312) 606-3240 mwethekam@saltlawyers.com
More informationwww.pwc.com Current issues in income tax accounting (US GAAP & IFRS)
www.pwc.com Current issues in income tax accounting (US GAAP & IFRS) May 16, 2012 Agenda Introductions Basic overview of the model Uncertain tax positions Unremitted foreign earnings Special topics (Intraperiod
More informationAnnual Banking Workshop Tax Update
Jeffrey A. Ring, CPA, MST Annual Banking Workshop Tax Update berrydunn.com ON TRACK WITH YOUR AGENDA Review of recent guidance, tax credits, BASEL III tax computations and state nexus matters Bad Debt
More informationIRS PROCEDURAL ISSUES
IRS PROCEDURAL ISSUES I. Introduction A. In general, IRS procedural issues involving organizations that are, are seeking to become, or claim to be exempt from Federal income tax are the same as those for
More informationAMERICA CAN! CARS FOR KIDS
ANNUAL FINANCIAL REPORT FOR THE YEAR ENDED AUGUST 31, 2014 C O N T E N T S Page INDEPENDENT AUDITOR S REPORT... 1 FINANCIAL STATEMENTS Statement of Financial Position... 3 Statement of Activities... 4
More informationIRS Administrative Appeals Process Procedures
IRS Administrative Appeals Process Procedures Charles P. Rettig Avoiding litigation is often the best choice for a client. The Administrative Appeals process can make it happen. Charles P. Rettig, a partner
More informationHow To Calculate Cash Flow From Operating Activities
Lawson Software, Inc. 10 Q Quarterly report pursuant to sections 13 or 15(d) Filed on 10/8/2009 Filed Period 8/31/2009 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 10 Q
More informationMarch 2012. Tax accounting services: Key areas of focus when accounting for income taxes during interim periods
March 2012 Tax accounting services: Key areas of focus when accounting for income taxes during interim periods Tax accounting services About this paper At the close of every quarter, companies recognize
More informationCOLLEGE ACCESS FOUNDATION OF CALIFORNIA
CONSOLIDATED FINANCIAL STATEMENTS C O N T E N T S Page Independent Auditors Report 1 Consolidated Statements of Financial Position 2 Consolidated Statements of Activities and Changes in Net Assets 3 Consolidated
More informationDigital Unrest Legislation, Litigation and Other Policy Changes Impacting the Tech Sector
Michele Borens, Partner Charlie Kearns, Counsel June 17, 2014 Digital Unrest Legislation, Litigation and Other Policy Changes Impacting the Tech Sector Agenda Industry Trends Related to Digital Goods and
More informationFinancial Reporting for Taxes
Financial Reporting for Taxes TEI May A&A Update Meeting Acquisition accounting May 8, 2012 Orlando, FL Wendi Christensen Deloitte Tax LLP wendichristensen@deloitte.com Agenda Disclosures and supporting
More informationFlorida corporate income tax Reporting of federal audit adjustments. By Benjamin A. Jablow, Deloitte Tax LLP
Florida corporate income tax Reporting of federal audit adjustments By Benjamin A. Jablow, Deloitte Tax LLP Tax Law by Benjamin A. Jablow Florida Corporate Income Tax: Reporting of Federal Audit Adjustments
More informationLINCOLN INVESTMENT PLANNING, INC. AND SUBSIDIARIES. Consolidated Statement of Financial Condition Period Ended June 30, 2015
Consolidated Statement of Financial Condition Period Ended Consolidated Statement of Financial Condition Year Ended TABLE OF CONTENTS Page(s) Consolidated Statement of Financial Condition 1 2-10 Consolidated
More informationSTOCKCROSS FINANCIAL SERVICES, INC. REPORT ON AUDIT OF STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2012
REPORT ON AUDIT OF STATEMENT OF FINANCIAL CONDITION Filed in accordance with Rule 17a-5(e)(3) as a PUBLIC DOCUMENT UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 ANNUAL AUDITED
More informationAvoiding Tax Surprises In Trust And Estate Litigation: Transfer Tax Aspects Of Settlements
Avoiding Tax Surprises In Trust And Estate Litigation: Transfer Tax Aspects Of Settlements Julie K. Kwon A. Introduction 1. Parties negotiating the resolution of their disputes regarding interests in trusts
More informationUCLA ALUMNI ASSOCIATION (A NONPROFIT ORGANIZATION AFFILIATED WITH UCLA) FINANCIAL STATEMENTS FOR THE YEAR ENDED JUNE 30, 2009
FINANCIAL STATEMENTS FOR THE YEAR ENDED JUNE 30, 2009 CONTENTS Page INDEPENDENT AUDITOR'S REPORT 1 FINANCIAL STATEMENTS Statement of Financial Position 2 Statement of Activities 3 Statement of Changes
More informationWaive or Walk: Considerations for Extending the Statute of Limitations
Waive or Walk: Considerations for Extending the Statute of Limitations Jeffrey A. Friedman and Michael L. Colavito Jr. Jeffrey A. Friedman Michael L. Colavito Jr. Intuitively, most taxpayers likely assume
More informationFIN 48: What Every Nonprofit Needs to Know
FIN 48: What Every Nonprofit Needs to Know Jeffrey S. Tenenbaum, Esq. Matthew T. Journy, Esq. Association of Corporate Counsel Nonprofit Organizations Committee Legal Quick Hit January 12, 2010, 3:00-3:30
More informationMinnesota Workers' Compensation Assigned Risk Plan. Financial Statements Together with Independent Auditors' Report
Minnesota Workers' Compensation Assigned Risk Plan Financial Statements Together with Independent Auditors' Report December 31, 2012 CONTENTS Page INDEPENDENT AUDITORS' REPORT 1 FINANCIAL STATEMENTS: Balance
More informationCalifornia Interscholastic Federation Los Angeles City Section (A Nonprofit Organization) Financial Statements June 30, 2014
California Interscholastic Federation Los Angeles City Section Financial Statements INDEX TO FINANCIAL STATEMENTS Independent Auditors Report... 1 Statement of Financial Position... 3 Statement of Activities...
More informationState Income Tax Issues for Professional Service Firms. by Gerald A. Shanker
State Income Tax Issues for Professional Service Firms by Gerald A. Shanker State Income Tax Issues for Professional Service Firms by Gerald A. Shanker Facing continuing budget deficits, state governments
More informationIncome Taxes (Topic 740)
No. 2009-06 September 2009 Income Taxes (Topic 740) Implementation Guidance on Accounting for Uncertainty in Income Taxes and Disclosure Amendments for Nonpublic Entities An Amendment of the FASB Accounting
More informationFinancial Statements and Report of Independent Certified Public Accountants. The California Wellness Foundation. December 31, 2014 and 2013
Financial Statements and Report of Independent Certified Public Accountants The California Wellness Foundation December 31, 2014 and 2013 Contents Page Report of Independent Certified Public Accountants
More informationNotes to Financial Statements - Summary of Significant Accounting Policies (1)
Audited Financial Statements June 30, 2011 and 2010 Contents Independent Auditors' Report... 1 Financial Statements: Statements of Financial Position... 2 Statement of Activities... 3 Statement of Cash
More informationTaxation of Nonresidents and Individuals Who Change Residency
State of California Franchise Tax Board Taxation of Nonresidents and Individuals Who Change Residency FTB Publication 1100 (REV 04-2014) For forms and information, go to ftb.ca.gov and search for forms
More informationDefining Issues. FASB Simplifies Accounting for Share-based Payments. April 2016, No. 16-11
Defining Issues April 2016, No. 16-11 FASB Simplifies Accounting for Share-based Payments The FASB recently issued an Accounting Standards Update (ASU) intended to improve the accounting for share-based
More informationMOZILLA FOUNDATION DECEMBER 31, 2011 AND 2010 INDEPENDENT AUDITORS' REPORT CONSOLIDATED FINANCIAL STATEMENTS AND SUBSIDIARIES AND
MOZILLA FOUNDATION AND SUBSIDIARIES DECEMBER 31, 2011 AND 2010 INDEPENDENT AUDITORS' REPORT AND CONSOLIDATED FINANCIAL STATEMENTS Independent Auditors' Report and Consolidated Financial Statements Independent
More informationFINANCIAL STATEMENTS. For the Years Ended March 31, 2014 and 2013 with Independent Auditors Report
FINANCIAL STATEMENTS For the Years Ended with Independent Auditors Report FINANCIAL STATEMENTS CONTENTS Page Independent Auditors Report... 1-2 Financial Statements: Statements of Financial Position...3
More informationSilicon Valley Independent Living Center (A California Nonprofit Public Benefit Corporation)
Silicon Valley Independent Living Center (A California Nonprofit Public Benefit Corporation) FINANCIAL STATEMENTS AND SUPPLEMENTARY INFORMATION Year Ended June 30, 2010 with Comparative Totals For the
More informationPINK OTC MARKETS. DALRADA FINANCIAL CORPORATION (A Delaware Company)
PINK OTC MARKETS DALRADA FINANCIAL CORPORATION (A Delaware Company) QUARTERLY REPORT: For the Three and Nine Months ended March 31, 2012 and 2011 Contents: Section (I) Dalrada Financial Corporation Quarterly
More informationState of California Franchise Tax Board. Audit / Protest / Appeals (The process)
State of California Franchise Tax Board Audit / Protest / Appeals (The process) Table of Contents Introduction / 3 Before the Audit / 4 Audit Procedures / 5 After the Audit / 10 Notice of Proposed Assessment
More informationSales Tax Issues Impacting Not-for- Profit Organizations
Sales Tax Issues Impacting Not-for- Profit Organizations June 8, 2012 1:00-2:15 p.m. Content Leaders: Emily Cummins, CPA, CPCU, ARM, ARe, director, tax & risk management, National Rifle Association of
More informationNew Developments Summary
April 15, 2008 NDS 2008-17 Revised for FASB Codification July 1, 2009 New Developments Summary Business combinations FASB Statement 141 (revised 2007) (ASC 805) Summary On December 4, 2007, the FASB issued
More informationFinancial Statements Together with Report of Independent Certified Public Accountants FJC. March 31, 2015 and 2014
Financial Statements Together with Report of Independent Certified Public Accountants FJC TABLE OF CONTENTS Page Report of Independent Certified Public Accountants 1-2 Financial Statements Statements of
More informationFinancial Statements. August 31, 2013 and 2012. (With Independent Auditors Report Thereon)
Financial Statements (With Independent Auditors Report Thereon) Table of Contents Page Independent Auditors Report 1 Statements of Financial Position 2 Statement of Activities Year ended August 31, 2013
More informationAudit and Permitted Non-Audit Services Pre-Approval Policy (Pertaining to the Company s Independent Auditor)
Audit and Permitted Non-Audit Services Pre-Approval Policy (Pertaining to the Company s Independent Auditor) Statement of Principles Pursuant to the Sarbanes-Oxley Act of 2002 (the Act ) and in accordance
More informationSUBJECT Income Tax Accounting Question & Answer Series #3 ACCOUNTING IMPLICATIONS FROM THE TANGIBLE PROPERTY REPAIR REGULATIONS CONTACT: BACKGROUND
BDO STATE AND LOCAL TAX ALERT 1 DECEMBER 2014 www.bdo.com SUBJECT Income Tax Accounting Question & Answer Series #3 ACCOUNTING IMPLICATIONS FROM THE TANGIBLE PROPERTY REPAIR REGULATIONS PREFACE: There
More informationBusiness for Social Responsibility. Consolidated Financial Statements. December 31, 2012 (With Comparative Totals for 2011)
Business for Social Responsibility Consolidated Financial Statements (With Comparative Totals for 2011) TABLE OF CONTENTS Page No. Independent Auditor's Report 1-2 Consolidated Statement of Financial Position
More informationJune 2010 State Tax Return
June 2010 State Tax Return Volume 17 Number 2 Colorado Leads the Charge: Adopts Affiliate Nexus and New Notice and Reporting Requirements for Sales Tax and Economic Nexus Rules for Income Tax Laura A.
More informationUCLA ALUMNI ASSOCIATION (A NONPROFIT ORGANIZATION AFFILIATED WITH UCLA) FINANCIAL STATEMENTS FOR THE YEARS ENDED JUNE 30, 2012 AND 2011
FINANCIAL STATEMENTS FOR THE YEARS ENDED JUNE 30, 2012 AND 2011 CONTENTS Page INDEPENDENT AUDITOR S REPORT 1 FINANCIAL STATEMENTS Statements of Financial Position 2 Statements of Activities 3 Statements
More informationNATIONAL BANK OF CANADA FINANCIAL INC. AND SUBSIDIARIES
Consolidated statement of financial condition as of and independent auditor s report and supplemental report on internal control NATIONAL BANK OF CANADA FINANCIAL INC. (SEC I.D. No. 8-39947) Table of Contents
More informationExpert Access Seminar Series: Tax Accounting 101 September 14, 2011
www.pwc.com Expert Access Seminar Series: Tax Accounting 101 September 14, 2011 Introduction to Tax Accounting Robin DarrenCaicco Speake (905) (416) 777-7003 869 2471 Robin.T.Caicco@ca.pwc.com darren.speak@ca.pwc.com
More informationUNITED STATES OF AMERICA
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 70448 / September 18, 2013 ACCOUNTING AND AUDITING ENFORCEMENT Release No. 3487 / September
More informationSUGGESTED PROCEDURE FOR FILING AND PERFECTING PROTECTIVE CLAIMS UNDER TREASURY REGULATIONS 20.2053-1
SUGGESTED PROCEDURE FOR FILING AND PERFECTING PROTECTIVE CLAIMS UNDER TREASURY REGULATIONS 20.2053-1 I. BRIEF BACKGROUND by Robin L. Klomparens DISCUSSION IRC 2053(a)(3) states, in relevant part, that,
More informationAvoiding Career Limiting Mistakes: Monitoring Statutes of Limitations and Waivers and Preserving State Privileges
Jonathan A. Feldman Jeffrey A. Friedman TEI Audits & Appeals Seminar May 21, 2015 Avoiding Career Limiting Mistakes: Monitoring Statutes of Limitations and Waivers and Preserving State Privileges Agenda
More informationLUTHERAN FOUNDATION OF THE SOUTHWEST. Financial Statements as of and for the Years Ended December 31, 2014 and 2013 and Independent Auditors Report
LUTHERAN FOUNDATION OF THE SOUTHWEST Financial Statements as of and for the Years Ended December 31, 2014 and 2013 and Independent Auditors Report MAXWELL LOCKE & RITTER L L P Accountants and Consultants
More informationRelief from Effects of Amazon Laws - Multistate Tax Commission Voluntary Disclosure
Relief from Effects of Amazon Laws - Multistate Tax Commission Voluntary Disclosure by Betty J. Williams 1 and Ulises Pizano-Diaz 2 Given the current economic climate and the ever increasing global nature
More informationTHE ASPEN EDUCATION FOUNDATION FINANCIAL STATEMENTS. June 30, 2013
FINANCIAL STATEMENTS June 30, 2013 FINANCIAL STATEMENTS June 30, 2013 TABLE OF CONTENTS ITEM PAGE NUMBER Independent Auditor s Report 1 Statement of Financial Position 2 Statement of Activities 3 Statement
More informationARIZONA INDIVIDUAL ESTIMATED INCOME TAX PAYMENTS
This publication is designed to provide general information with respect to the Arizona individual income tax estimated payment requirements. For complete details, refer to the Arizona Revised Statutes.
More informationDevelopments in Sourcing
TEI - Denver Chapter May 13, 2015 Michele Borens Marc Simonetti Developments in Sourcing Agenda Introduction Market Sourcing Professional Services E-Services Financial Services Cable Service 2 3 Market
More informationCOST 44 th Annual Meeting
COST 44 th Annual Meeting Dealing with Debt in Related Entity Groups October 23, 2013 2:20 3:10 a.m. Giles Sutton Jeffrey M. Vesely Grant Thornton LLP Pillsbury Partner, State & Local Tax Partner 704.632.6885
More informationPRESENT LAW AND BACKGROUND RELATING TO WORKER CLASSIFICATION FOR FEDERAL TAX PURPOSES
PRESENT LAW AND BACKGROUND RELATING TO WORKER CLASSIFICATION FOR FEDERAL TAX PURPOSES Scheduled for a Public Hearing before the SUBCOMMITTEE ON SELECT REVENUE MEASURES and the SUBCOMMITTEE ON INCOME SECURITY
More informationFiling Claims for Refund of Sales or Use Tax
State of Wisconsin Department of Revenue Important Change The football stadium district tax in Brown County ends on September 30, 2015. Filing Claims for Refund of Sales or Use Tax Includes information
More informationMOZILLA FOUNDATION DECEMBER 31, 2014 AND 2013 INDEPENDENT AUDITORS REPORT CONSOLIDATED FINANCIAL STATEMENTS AND SUBSIDIARY AND
MOZILLA FOUNDATION AND SUBSIDIARY DECEMBER 31, 2014 AND 2013 INDEPENDENT AUDITORS REPORT AND CONSOLIDATED FINANCIAL STATEMENTS Independent Auditors Report and Consolidated Financial Statements Independent
More informationACCOUNTING FOR SALES TAX PROFESSIONALS
ACCOUNTING FOR IPT ANNUAL CONFERENCE SALES TAX PROFESSIONALS Suzanne Wilson Jeff McGhehey, CMI Sr. Mgr. Transaction Tax Sr. Mgr. Indirect Tax American Airlines The Home Depot Phoenix, AZ Atlanta, GA Suzanne.Wilson@AA.com
More informationCynk Technology Corp. (A Development Stage Company) (formerly Introbuzz) Balance Sheets
Cynk Technology Corp. (A Development Stage Company) (formerly Introbuzz) Balance Sheets ASSETS March 31, December 2014 31, 2013 ------- --------- Current Assets Cash and cash equivalents $ 39 $ 39 --------
More informationTIGER X MEDICAL, INC.
TIGER X MEDICAL, INC. FORM 10-Q (Quarterly Report) Filed 05/03/16 for the Period Ending 03/31/16 Address 10900 WILSHIRE BOULEVARD, SUITE #1500 LOS ANGELES, CA 90024 Telephone (310) 987-7345 CIK 0000925741
More informationNegotiating the Tax Provisions of Acquisition (Disposition) Agreements
Negotiating the Tax Provisions of Acquisition (Disposition) Agreements Daniel Leightman Gardere Wynne Sewell HBA M&A Section Meeting November 21, 2013 Houston, Texas Role Of Various Professionals In The
More informationFREEDOM INVESTMENTS, INC. STATEMENT OF FINANCIAL CONDITION AS OF JUNE 30, 2015 (UNAUDITED)
FREEDOM INVESTMENTS, INC. STATEMENT OF FINANCIAL CONDITION AS OF JUNE 30, 2015 (UNAUDITED) ****** Index Page(s) Statement of Financial Condition. 2 Notes to Statement of Financial Condition. 3-5 Statement
More informationCHAPTER 10 PAYROLL TAXES BONUSES EXPENDITURE CYCLE: OTHER OPERATING ITEMS
CHAPTER 10 EXPENDITURE CYCLE: OTHER OPERATING ITEMS 1 PAYROLL TAXES Employee payroll taxes: Federal income tax State income tax FICA taxes Employer payroll taxes: FICA taxes Federal unemployment taxes
More informationDeferred income tax assets: Allowance for doubtful accounts 30,000 25,000 Tax loss carryforwards 100,000 100,000 Accruals and other 20,000 25,000
Handout 1 LOL Draft Income Statement and Excerpt From Tax Footnote as of December 31, 2010 LOL Corporation CONSOLIDATED STATEMENT OF OPERATIONS Years ended December 31, 2010, 2009, and 2008 (in thousands)
More informationScheduled for a Public Hearing. Before the SENATE COMMITTEE ON FINANCE. on April 5, 2001. Prepared by the Staff. of the JOINT COMMITTEE ON TAXATION
OVERVIEW OF PRESENT LAW RELATING TO THE INNOCENT SPOUSE, OFFERS-IN-COMPROMISE, INSTALLMENT AGREEMENT, AND TAXPAYER ADVOCATE PROVISIONS OF THE INTERNAL REVENUE CODE Scheduled for a Public Hearing Before
More informationPYXIS SOLUTIONS, LLC, USA
PYXIS SOLUTIONS, LLC, USA REPORT OF THE CHIEF EXECUTIVE OFFICER TO THE SOLE MEMBER, ITC INFOTECH (USA), INC. I take pleasure in presenting my Report together with the Audited Financial Statements of the
More informationSpecial Report Sales Tax Study
Special Report Sales Tax Study February 2001 City Auditor s Office City of Kansas City, Missouri 13-2001 February 7, 2001 Honorable Mayor and Members of the City Council: We conducted this study to identify
More informationBankruptcy Filing and Federal Employment Taxes. Bad investments, too great an assumption of risk, circumstances beyond their control.
I. What causes someone to file for bankruptcy? Bad investments, too great an assumption of risk, circumstances beyond their control. II. The options A. Individuals Chapter 7, Chapter 11, i Chapter 13 B.
More informationTREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION Many Taxpayers Are Still Not Complying With Noncash Charitable Contribution Reporting Requirements December 20, 2012 Reference Number: 2013-40-009 This
More informationFIRST PRIORITY TAX SOLUTIONS INC.
FIRST PRIORITY TAX SOLUTIONS INC. FORM 10-Q (Quarterly Report) Filed 05/20/15 for the Period Ending 03/31/15 Address 137 N. MAIN STREET SUITE 200A DAYTON, OH 45402 Telephone 859-268-6264 CIK 0001622408
More informationMAKE-A-WISH FOUNDATION OF MASSACHUSETTS AND RHODE ISLAND, INC. Financial Statements. August 31, 2014. (With Independent Auditors Report Thereon)
MAKE-A-WISH FOUNDATION OF MASSACHUSETTS Financial Statements (With Independent Auditors Report Thereon) Table of Contents Page Independent Auditors Report 1 Statement of Financial Position 3 Statement
More informationCOLORADO DEPARTMENT OF REVENUE GUIDE TO THE MANAGED AUDIT PROGRAM FOR SALES AND USE TAXES
GUIDE TO THE FOR SALES AND USE TAXES AS OF June 29, 2007 Contents Preface Introduction to the Managed Audit Program............... 3 Reviewing your sales.................................... 5 Reviewing
More informationApex Clearing Corporation
Statement of Financial Condition (Unaudited) Apex Clearing Corporation is a member of FINRA, Securities Investor Protection Corporation (SIPC), NYSE MKT LLC, NYSE Arca, Inc., BATS Y Exchange, Inc., BATS
More informationFinancial Institution Tax Provision Calculations. Michael J. Rowe, CPA August 18, 2015
Financial Institution Tax Provision Calculations Michael J. Rowe, CPA August 18, 2015 MEMBER OF PKF NORTH AMERICA, AN ASSOCIATION OF LEGALLY INDEPENDENT FIRMS 2010 Wolf & Company, P.C. Before we get started
More informationSeptember 30, 2015 and 2014
Combined Financial Statements and Report of Independent Certified Public Accountants Corporation for Public Broadcasting and Affiliate Contents Report of Independent Certified Public Accountants 3 4 Financial
More informationThe Depository Trust Company
The Depository Trust Company Unaudited Condensed Consolidated Financial Statements as of March 31, 2016 and December 31, 2015 and for the three months ended March 31, 2016 and 2015 THE DEPOSITORY TRUST
More informationCondensed Interim Financial Statements Fiscal 2012 - First Quarter (Unaudited) For the three month periods ended July 31, 2011 and 2010
Condensed Interim Financial Statements Fiscal 2012 - First Quarter (Unaudited) For the three month periods ended July 31, 2011 and 2010 CRITICAL OUTCOME TECHNOLOGIES INC. Page 2 Condensed Interim Financial
More informationTAX TREATMENT OF RECOVERIES IN EMPLOYMENT DISPUTES
TAX TREATMENT OF RECOVERIES IN EMPLOYMENT DISPUTES Committee on Labor & Employment Law AUGUST 2009 THE ASSOCIATION OF THE BAR OF THE CITY OF NEW YORK 42 WEST 44 TH STREET, NEW YORK, NY 10036 TAX TREATMENT
More informationInquiry of a Client s Lawyer Concerning Litigation, Claims, and Assessments: Auditing Interpretations of Section 337
Inquiry of a Client s Lawyer 2017 AU Section 9337 Inquiry of a Client s Lawyer Concerning Litigation, Claims, and Assessments: Auditing Interpretations of Section 337 1. Specifying Relevant Date in an
More informationPursuit Management, Inc. dba: MobileSpike Technologies, Inc. Financial Statements and Independent Accountants Review Report December 31, 2015 and
Financial Statements and Independent Accountants Review Report December 31, 2015 and 2014 Financial Statements Contents INDEPENDENT ACCOUNTANTS REVIEW REPORT 1 Page FINANCIAL STATEMENTS: Balance sheets
More informationObjective. Background FSP FAS 142-3 FASB STAFF POSITION. No. FAS 142-3. Title: Determination of the Useful Life of Intangible Assets
FASB STAFF POSITION No. FAS 142-3 Title: Determination of the Useful Life of Intangible Assets Date Posted: April 25, 2008 Objective 1. This FASB Staff Position (FSP) amends the factors that should be
More informationPROSPECTUS. Aflac Incorporated Worldwide Headquarters 1932 Wynnton Road Columbus, Georgia 31999 1.800.227.4756-706.596.3589
PROSPECTUS Aflac Incorporated Worldwide Headquarters 1932 Wynnton Road Columbus, Georgia 31999 1.800.227.4756-706.596.3589 AFL Stock Plan A Direct Stock Purchase and Dividend Reinvestment Plan We are offering
More informationUrology Care Foundation, Inc. Financial Report December 31, 2012
Urology Care Foundation, Inc. Financial Report December 31, 2012 Contents Independent Auditor s Report On The Financial Statements 1 2 Financial Statements Statements Of Financial Position 3 Statements
More informationDefining Issues. U.S. Health Care Reform Creates Potential Accounting and Disclosure Changes
Defining Issues April 2010, No. 10-20 KPMG LLP U.S. Health Care Reform Creates Potential Accounting and Disclosure Changes The recently approved health care reform law could have significant accounting
More informationOnline Sales Taxes and E-Fairness
Georgia Chamber of Commerce s 2011 Tax Forum November 3, 2011 Stephen Kranz Sutherland Asbill & Brennan LLP Washington, D.C. Warren Townsend Wal-Mart Stores, Inc. Bentonville, AR Online Sales Taxes and
More informationSETTLEMENT GUIDELINES. Claim Revenue Under A Long-Term Contract
SETTLEMENT GUIDELINES Claim Revenue Under A Long-Term Contract STATEMENT OF ISSUE Whether a taxpayer must include "claim revenue" in the total contract price in determining the gross income from a long-term
More informationASPIRE CHARTER ACADEMY, INC. A Charter School and Component Unit of the District School Board of Orange County, Florida
Financial Statements with Independent Auditors Reports Thereon June 30, 2015 CONTENTS Page Management s Discussion and Analysis 1 6 Report of Independent Auditors on Basic Financial Statements and Supplementary
More informationINTELLECTUAL PROPERTY ASPECTS OF DOING BUSINESS IN CHINA
From PLI s Online Program FAS 161 and FAS 133: Where Are We Now and Where Are We Going 2008? #17758 5 INTELLECTUAL PROPERTY ASPECTS OF DOING BUSINESS IN CHINA Elizabeth Chien-Hale Institute for Intellectual
More informationPublic Library of Science. Financial Statements
Public Library of Science Financial Statements TABLE OF CONTENTS Page No. Independent Auditor's Report 1-2 Statement of Financial Position 3 Statement of Activities 4 Statement of Functional Expenses 5
More informationAdviser alert Deferred tax a Chief Financial Officer s guide to avoiding the pitfalls (revised guide)
Adviser alert Deferred tax a Chief Financial Officer s guide to avoiding the pitfalls (revised guide) February 2013 Overview The Grant Thornton International IFRS team has published a revised version of
More information