Recognition[edit]
Income tax expense, just as any other expense, must be generally recognized when income is earned. Credits or other items that reduce this tax are recognized only if it is more likely than not that the reductions will be sustained by tax authorities. FIN 48 clarifies several aspects of this process:
Analysis is at the "unit of account" rather than in aggregate
The "more likely than not" standard applies at this level
It is presumed that all positions will be examined, and tax authorities will have full knowledge of all relevant information
Whether a position can be sustained is based solely on the technical merits of the position
The level of detail of the analysis (unit of account) depends on how the business keeps its records, presents its financial statements, and deals with tax authorities. This may vary from business to business, and may change over time. Further, materiality is determined at the unit of account level.
One key clarification is the presumption of examination of all positions by knowledgeable tax authorities and a resolution of disputes over those positions solely on the technical merits of each position. All relevant tax law is to be considered for the individual position. Positions that are not technically correct are allowed only where there is widely understood administrative practice allowing the position.[3] Thus, for example, a position would not be acceptable merely because an Internal Revenue Service agent allowed it in a previous year.