FIN 48: What your clients will expect from you
Tuesday, December 19, 2006
4:00 p.m. - 7:00 p.m.
Social Law Library
John Adams Courthouse
One Pemberton Square, Boston
Sponsors
Tax Section
New FASB Interpretation 48 on Accounting for Uncertainty in Income Taxes (“FIN 48”) will soon become effective, setting new thresholds for recognizing and measuring the benefits of a company’s tax return positions in its financial statements. Implementation of these new rules will likely present a major undertaking for companies, requiring an examination of not only current but also prior reporting positions. The role of attorneys in this process will significantly expand as companies struggle to classify their tax return positions under these new standards. In addition, attorneys need to understand how these requirements for recognizing tax benefits on financial statements will affect planning for acquisitions and divestitures, as well as how the interpretation’s new disclosure provisions could create a road map for tax authorities to attack tax planning structures.
A panel of experts from the “Big four” accounting firms and academia willl take us through the ins-and-outs of these issues and the related planning opportunities.
Agenda:
1) A general introduction to tax provisions and the FAS 109 rules.
2) The basic requirements of FIN 48 and the role of attorneys in the process (including meeting the more-likely-than-not standard).
3) The FIN 48 disclosure requirements.
4) Whether FIN 48 disclosure creates a road map for an IRS audit.
5) How FIN 48 affects confidentiality issues surrounding attorney and accountant work product and opinions.
6) Specific applications of the FAS 109 and FIN 48 standards in the context of a merger and acquisitions practice.
Panelists
William J. Connolly
KPMG LLP
Joseph DeQuattro
Ernst & Young LLP
Pauline W. Mak
KPMG LLP
Arnold R. Rosenfeld, Esq.
Kirkpatrick & Lockhart Nicholson Graham LLP
Visiting Professor, Boston University School of Law
Program Co-Chairs
David M. Sheehan, Esq.
KPMG LLP
Christopher M. Flanagan, Esq.
Edwards Angell Palmer & Dodge LLP
*CPE Credit Avaliable
Program Prices
$120 - BBA Members
$155 - Non-Members
$85 - BBA Sponsoring Section Member
$65 - BBA Member Legal Services/Government Lawyer
$25 - Law Student
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