FIN 48 is an interpretation note on FAS 109. It affects all private and public entities preparing accounts in accordance with US GAAP. The interpretation applies to all 'tax positions' including tax benefits, accruals etc related to income taxes subject to FAS 109.
Complexities will arise for funds in identifying uncertain tax positions under FIN 48 due to the international nature of their business. Challenges will include assessing whether and to what extent tax uncertainties arise in diverse geographical locations including the country where the investment manager/advisor is located, where the fund is invested and also where the fund is marketed.
