Nov 2009 FIN 48 addresses accounting and disclosure requirements of Uncertain Tax Positions ("UTPs") under US GAAP. Previously funds and their portfolio companies were not required to comply with FIN 48. However, it is currently expected that for accounting periods commencing on or after 15 December 2008 (ie in the 12 month accounts to 31 December 2009, in many cases) funds and their portfolio companies who prepare US GAAP accounts will need to adopt FIN 48. The attached article explains how UTPs are calculated under FIN 48, how this may effect funds and portfolio companies who prepare US GAAP accounts and outlines common local tax issues that may result in UTPs.
If you are responsible for preparing US GAAP accounts, or a fund where portfolio company(ies) prepare US GAAP accounts you are likely to have to perform significant work to determine and calculate these entities' FIN 48 position prior to year end.
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FIN 48: the adoption by non-public companies - the effect on funds and portfolio investments (pdf file, 193KB) for your reference.
