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Can CPAs help attest clients apply FIN 48 (FASB Interpretation No. 48, Accounting for Uncertainty in Income Taxes) without impairing independence, given the potential complexity of the judgments that the client must make or approve in connection with such services?
That question is the subject of recent non-authoritative guidance from the AICPA's Professional Ethics Executive Committee (PEEC).
The verdict
The provision of such services would not impair independence, provided:
* The client can make an informed judgment on the results of the member's services
* Other requirements of Interpretation 101-3 are met
In meeting the requirements of Interpretation 101-3, the member may assist the client in understanding why the tax positions do or do not meet the more-likely-than-not (MLTN) threshold and the basis for any unrecognized tax benefit so that the client can accept responsibility for the amounts reported and disclosed in the financial statements.
Source: HighBeam Research, The ethical implications of FIN 48.(Issue update)