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As you should be aware, FIN 48 (Accounting for Uncertainty in Income Tax - An Interpretation of FASB Statement No. 109) is effective for fiscal years beginning after December 15, 2007. FIN 48 applies to all non-public enterprises that prepare GAAP financial statements, including non-profit organizations and other entities whose tax liability is subject to 100% credit for dividends paid (i.e., real estate investment trusts and registered investment companies) that are potentially subject to income taxes. Additionally, non-U.S. based enterprises that issue financial statements based on or reconciled to U.S. GAAP are subject to FIN 48 as well.

Compliance is mandatory. No delays or exceptions look to be forthcoming. Companies should be addressing FIN 48 now as:

• Failure to comply can certainly lead to a delay in the issuance of any audit report.
• Dealing with FIN 48 now will give you the flexibility and time needed to make smart business decisions. It is nearly always easier to make compliance decisions when the clock is in your favor.
• Upfront tax planning can minimize the tax exposure surrounding your company.

If you have not already discussed the impact that FIN 48 may have on your company, it is imperative to reach out to an Amper representative right away. As with so many things, proper planning is the key to success with implementing FIN 48.