uncertain tax positions examples

What amount of tax benefit should be recognized in Granny Smiths financial statements? 2022. This Interpretation clarifies how to apply the recognition and measurement Accordingly, B cannot recognize the $350,000 tax benefit in 2015. This will involve a substantial amount of subjectivity, since the tax law is rarely clear in new or complicated situations, particularly when the facts play a critical role in what the tax consequences of a transaction will be. A company must disclose the total amount of interest and penalties recognized in the income statement and the total amounts of interest and penalties recognized in the statement of financial position. As an example, subpart f qualified deficits may only be used to the extent the company earns subpart f income . As a result, the accounting for uncertain tax positions under ASC 740 is in the spotlight. take on its tax return. Example 1. However, there is no right of appeal to the Supreme Court. Schedule UTP draft form and instructions. Approach to tax, principal risks, uncertain tax positions, OECD initiative, judgements and estimates Income taxes, reconciliation of current income tax liability Standards issued but not yet effective, IAS 12 amendment to introduce an exception to the initial recognition exemption for transactions that give rise to equal taxable and deductible . Tax Items has the meaning set forth in Section 6.4.A hereof. Get the tax expertise and tools with our provision software and research platform request pricing now. We recommend that companies and their auditors brush up on this important accounting topic. They do not apply to indirect taxes, for example Goods and Services Tax or State Taxes such as stamp duties and payroll tax. A corporations complete and accurate disclosure of a tax position on the appropriate years Schedule UTP, Uncertain Tax Position Statement, is treated as if the corporation had filed a Form 8275 or Form 8275-R regarding the tax position. Tax law is subject to interpretation and it may be uncertain as to whether a tax position taken by a company will be sustained upon review. Production Tax Credit or PTC means the tax credit for electricity produced from certain renewable generation resources described in Section 45 of the Internal Revenue Code of 1986, as it may be amended or supplemented from time to time. Granny Smith considers the amounts and probabilities (if challenged) of the possible estimated outcomes as follows: Granny Smith uses U.S. GAAP and its income tax rate is 30%. If the uncertainty relates to the timing of the deduction rather than the deductibility itself, record a deferred tax asset related to the position with an offsetting credit to deferred income tax expense. For positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly increase or decrease within 12 months of the reporting date; the company must disclose the following: Learn the fundamentals of ASC 740, how to calculate the tax provision, and how to make the process easier. To recognize any benefit, the client must believe it is more likely than not that the court of last resort would sustain the position. A company is required to make several disclosures with respect to uncertain tax positions. Mike Walworth, CPA . Actual Tax Liability means, with respect to any Taxable Year, the sum of (i) the sum of (A) the liability for U.S. federal income Taxes of the Corporate Taxpayer and (B) without duplication, the portion of any liability for U.S. federal income Taxes imposed directly on OpCo (and OpCos applicable subsidiaries) under Section 6225 or any similar provision of the Code that is allocable to the Corporate Taxpayer under Section 704 of the Code, in each case using the same methods, elections, conventions and similar practices used on the relevant IRS Form 1120 (or any successor form) and (ii) the product of the amount of the U.S. federal taxable income for such taxable year reported on the Corporate Taxpayers IRS Form 1120 (or any successor form) and the Blended Rate. Not a subscriber? This analysis for the measurement test often depends on whether the position is an all or nothing position. Some examples of a change in facts and circumstances include: When there has been an examination or action by the taxing authorities When the tax rules have changed When the statute of limitations has expired on a tax return These rules clarify the accounting for uncertainty in income taxes recognized in a companys financial statements and establish rules for recognizing and measuring tax positions taken on the companys income tax return. With governments around the world scrambling for tax revenues, this topic has been thrust into the spotlight. A company must disclose the years that are open to examination for its major jurisdictions. Taxpayers must list "uncertain tax positions" on the schedule by ranking the positions in order of size (based on the actual tax reserve amounts for each uncertain tax position), but they are not required to disclose the amount of potential tax liability related to the uncertain tax position. Using this information, Subtopic 740-10 would require recording a tax benefit of $2,350, which is the largest cumulative benefit that has a more than 50% probability of being recognized. Non-U.S. Tax Person A person other than a U.S. Tax Person. FASB Statement No. Schedule UTP, Uncertain Tax Position Statement, effective beginning with 2010 tax returns for firms with $100 million or more in assets, requires firms to provide a narrative description of federal tax positions claimed in the current year for which a reserve is recorded in the financial statements.5 Thus, Schedule UTP enables the IRS to disaggregate financial statement reserves for tax aggressiveness. . Applying tax law to a companys facts is often subject to uncertainty. That uncertainty can arise from ambiguity in the law, case law or regulations, how the company applies the law to its facts, or even a lack of guidance regarding certain types of transactions. 109, Accounting for Income Taxes, does not provide specific guidance on how . The Communities account for the effect of any uncertain tax positions based on a "more likely than not" threshold to the recognition of the tax positions being sustained based. However, in determining the amount of tax benefit to recognize in the financial statements, the client can base that benefit on what tax deduction the taxing authority might likely allow in a settlement. This Portfolio describes FASB's two-step process for determining tax benefits that can be reported on the financial statements: (1) recognitiondetermine if the tax . Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org. Common examples of uncertain tax positions include characterizing gains or losses as capital gains or losses, claiming a tax credit, allocating income between jurisdictions (or not filing a return when a company believes it does not have nexus in a state or country), excluding income the company believes is taxexempt and taking a tax deduction. The creation of a list of probabilities presupposes that the client (or tax professional) has analyzed both the facts and the pertinent tax law in reaching the conclusions as to the likely outcomes. Assuming a tax benefit of USD 1.5 million (USD 5 million x 30%) was already recorded in the financial statements, a liability USD 300,000 (USD 1 million x 30%) should be recorded representing the difference between the benefit measured under ASC 740 of USD 1.2 million and the tax benefit claimed on the income tax return of USD 1.5 million. Once, however, the MLTN standard has been met, the value of the tax benefit must be calculated. For tax years beginning in 2014 and later, the asset threshold for reporting uncertain tax positions on Schedule UTP (Form 1120) decreased to $10 million. Income taxes payable (balance sheet)USD 300,000. The Uncertain Tax Position is calculated based upon historic US R&D claims and equates to around 20% of the outstanding US R&D claims. Upon analysis, B concludes that this position does not meet the MLTN standard. Meeting the More-Likely-Than-Not Standard, Employee retention credit: Navigating the suspension test, US clients with international tax issues: Five helpful tips, Capital loss rules limit deduction of fees paid to terminate merger agreement, Rolling over shares upon S corporations acquisition. Meeting the MLTN standard: B Inc. has been aggressive in deferring income to future years from the sale of services. NBU has taken an uncertain tax position on its return. Keep up-to-date on the latest insights and updates from the GAAP Dynamics team on all things accounting and auditing. uncertain tax position means any member 's items of income, deduction, exclusion, gain, loss, or credit, for any taxable year, related to any of the following: (a) the adoption of certain accounting methods set forth in schedule 1, (b) the application of such methods, (c) the application of treas. I thought the liability account of the journal entry is unrecognized tax liability/tax contingency reserve? Example Granny Smith, Inc. is a subsidiary of Orchard Co. Granny Smith claimed a tax deduction of USD 5 million on its tax return and in its financial statements related to head office royalty charges allocated to them by Orchard. It is remote that the taxing authority would examine or reexamine any aspect of the tax position. A zero net worth taxpayer is the type of taxpayer who has no net worth. Aug 22, 2017 at 11:39 AM, Winston: Interestingly the draft guidance now includes an example of where transfer pricing is uncertain by virtue of not being in accordance with HMRC's known position, which illustrates that transfer pricing uncertainties will not be exclusively confined to the provisions trigger. In preparing the financial statements, N analyzes its risk that some or all of the compensation will be disallowed by the IRS on audit. The classification of interest and penalties in the income statement is an accounting policy decision that should be consistently applied. However, a practitioner should make sure that the client understands the cost and risk associated with litigating versus settling the tax issue, and document that understanding to support the conclusion. Other potential disclosures Changes in tax rate Disclosure corporate income tax example 6 Income tax expense 6 (a) Income tax expense 6 (b) Significant estimates - uncertain tax position and tax-related contingency 6 (c) Reconciliation of expected income tax to estimated income tax expense 6 (d) Amounts recognised directly in equity The submitter asked whether, in its statement of financial position, an entity presents a liability related to uncertain tax treatments as a current (or deferred) tax liability or as a provision. If it includes interest and penalties in pretax income, the company will add back the penalties as a permanent item and add back the interest as a temporary item, resulting in a deferred tax asset but no impact on the tax rate. The analysis of the position must consider the underlying statute, tax treaty, committee reports (indicating legislative intent), regulations, administrative rulings, and case law as those authorities are applied to the facts and circumstances in the tax position. Although Subtopic 740-10 uses the court of last resort as the ultimate determination of whether any tax benefit can be recognized, it also clearly provides that a client, in measuring the amount of the tax benefit, should consider the ultimate tax benefit if the matter were settled. Since Tax Year 2010, Schedule UTP has been used by certain corporations to report uncertain tax positions. Deposits made to a tax authority for a contested UTP will reduce the noncurrent payable but will not be disclosed in the tabular rollforward, The nature of the event that could occur in the next 12 months that would cause the change, An estimate of the range of the reasonably possible change or a statement that the company cannot estimate the range. HMRC guidance A company must accrue the appropriate interest and penalties associated with its uncertain tax benefits. The company makes a policy election to either include interest and penalties related to uncertain tax positions as part of its pretax income or as a component of income tax expense. That's why regular tax-planning sessions are so important. Dont have access? Increases related to current year positions, Increases and decreases related to prior year positions, Settlements of positions with a taxing authority, Reductions to unrecognized tax benefits as a result of the lapse of the applicable statute of limitations, Interest and penalties that have been accrued to the noncurrent payable will not be disclosed in the tabular rollforward. Example 3. The determination is a matter of judgment based on all available evidence, including how the entity prepares and supports its income tax return and the approach the entity anticipates the taxing authority will take during an examination. Dr. Current income tax expense (income statement) USD 300,000, Cr. C cannot consider the audit results in determining whether the MLTN standard is met since the results of that audit do not constitute legal authority. The more-likely-than-not recognition threshold is met by the reporting date, The tax position is effectively settled through examination, negotiation or litigation, The statute of limitations for the relevant taxing authority to examine and challenge the tax position has expired. ALPHARETTA, Ga., Feb. 18, 2021 (GLOBE NEWSWIRE) -- Schweitzer-Mauduit International, Inc. ("SWM" or the "Company") (NYSE: SWM) reported earnings results for the three months and year ended December 31, 2020. Apportionment of income earned in other jurisdictions. Learn how Novo Building Products simplified its spreadsheet-heavy tax provision process with Bloomberg Tax Provision. Companies must consider all the facts and circumstances that occur after the reporting date but before the release of the financial statements. Take control of your tax provision process with an easy-to-use guide that breaks down the steps and helps you navigate the biggest hurdles with background, details, and examples of how ASC 740 interacts with various tax laws and corporate facts. For example, an entity's decision not to submit any income tax filing in a tax jurisdiction, or not to include particular income in taxable profit, is an uncertain tax treatment if its acceptability is uncertain under tax law. Hypothetical Tax Liability means, with respect to any Taxable Year, the liability for Taxes of (i) the Corporate Taxpayer and (ii) without duplication, EBS, but only with respect to Taxes imposed on EBS and allocable to the Corporate Taxpayer or to the other members of the consolidated group of which the Corporate Taxpayer is the parent, in each case using the same methods, elections, conventions and similar practices used on the relevant Corporate Taxpayer Return, but (i) using the Non-Stepped Up Tax Basis as reflected on the Exchange Basis Schedule including amendments thereto for the Taxable Year and (ii) excluding any deduction attributable to Imputed Interest for the Taxable Year. Normally, a client can file a tax return if there is substantial authority for the tax position or if the client has a reasonable basis for the position and discloses the position. Connecting decision makers to a dynamic network of information, people and ideas, Bloomberg quickly and accurately delivers business and financial information, news and insight around the world. In practice, companies can, for example, address this issue using a guideline that defines 'certain tax positions'. The entity does not intend to appeal or litigate any aspect of the tax position included in the completed examination. Change in Tax Classification has the meaning set forth in Section 5.2(h). Thus, the tax benefit recognized by a client can also depend on whether the client is willing to litigate the matter through the court of last resort or would likely settle for less tax benefit. Examples of tax positions that are subject to the Interpretation include a decision not to . Corporations filing Forms 1120, 1120-F, 1120-L, or 1120-PC must file Schedule UTP if total assets equal or exceed the applicable asset threshold for the tax year and the corporation reserved for a tax position in audited financial statements. What are the "hazards of litigation" the client faces in the matter? The IRS has provided an example of an acceptable description: "The taxpayer incurred support department costs that were allocated to various research projects based on a methodology the taxpayer considers reasonable. However, as discussed later, the measurement of the tax benefit is based on the tax benefit likely to be realized upon ultimate settlement with the pertinent taxing authority. Information that becomes available after the reporting date, but before the financial statements are issued, should not be used in assessing any tax benefit. IAS 12 Income Taxes does not specify how uncertainty in tax treatments is reflected in the measurement of current and deferred tax assets and liabilities. In applying the recognition and measurement tests, all information available on the reporting date should be considered, including the companys willingness to settle or litigate a position with the taxing authority. Interest and penalties are expensed on a gross basis in the period in which they accrue. amounts reported on the "unrecognized tax benefits for positions taken in prior years" line item typically represent an uncertain tax position taken in a prior year for which measurement has changed for one of two reasons: (1) the reporting entity met one of the subsequent recognition thresholds in asc 740-10-25 -8, or (2) new information For example, a depreciation decision might involve consideration at both the federal level and the state level. Unfortunately, there is virtually no statutory authority or case law on the issue. Uncertain Tax Positions. ASC 740 permits interest to be charged as either income tax expense or interest expense, while penalties may be recorded as income tax expense or another expense classification. Likewise, a practitioner can sign a return if the position has substantial authority or if the practitioner has a reasonable basis for the position and discloses that position. Taxpayers can choose to claim a zero net worth, negative net worth, or no net worth. Remember - FIN 48 applies only to income tax positions. The issue is whether the taxpayer's method of allocating costs is acceptable by the IRS." Governments all over the world are in debt and are looking for additional tax revenues. Since the tax benefit can depend on whether the client is willing to litigate the issue, how willing is the client to fight an adverse determination? In evaluating the technical merits of a particular tax position, a company may only consider past examination activity to the extent that the taxing authority explicitly agreed to the item. 2022 Bloomberg Industry Group, Inc. All Rights Reserved. This guide summarizes the accounting literature related to accounting for income taxes. This portfolio analyzes the rules in FASB Accounting Standards Codification Topic 740 (ASC 740), Accounting for Income Taxes, and its international counterpart, IASC International Accounting Standard 12, Income Taxes. Fin 48 is required only under United States Generally Accepted Accounting Principles (US-GAAP) and is not present in international accounting standards. For ASC 740, a tax position is any position in a previously filed tax return or a position the company expects to take on a future tax return. It was just a matter of weeks before we had full implementation and recreation of our prior year provision ready to go. The measurement of such tax-return positions is based on the largest benefit that is greater than 50% likely of being realized. Not filing income tax returns in a state, local or foreign jurisdiction for unrelated business activities conducted in that jurisdiction. This will create three possible reporting situations: It is clear that Subtopic 740-10 requires a substantial amount of professional judgment to determine the appropriate unit of account, the likelihood that the MLTN standard will be met, and the probability of recognizing a tax benefit. An important factor in this analysis is that the information considered must be available on the reporting date. The deferred tax asset related to a particular carryforward represents the amount estimated to be sustained upon examination. Consider the client's and practitioner's experience with the taxing authority. The asset threshold for tax years 2010 and 2011 was $100 million, and it decreased to $50 million for tax years 2012 and 2013. For example, transfer pricing UTBs may result in offsetting benefits in the tax jurisdiction of the trading partner. Uncertain tax positions regarding unrelated business income also could include: Allocation of expenses against unrelated business income. On 1 April, 2022, the new notification of Uncertain Tax Treatment ("UTT") regime became live. When disclosures do not meet the requirements set forth in the Schedule UTP instructions, Letter 5191 is mailed to the taxpayer. Tel: +63 (2) 8845 2728. But uncertainty may exist. For example, tax departments need to understand if they are knowledgeable about administrative practices with respect to a tax position, and if they are not, be willing to seek outside assistance. This requires an analysis of possible outcomes and the probabilities of those outcomes. In making the recognition threshold assessment, a company assumes that the taxing authority will examine the position and have full knowledge of all relevant information. Tax Item means any item of income, gain, loss, deduction or credit, or other attribute that may have the effect of increasing or decreasing any Tax. Midlothian, Virginia 23114, Curious what an accountant can learn from an eLearning conference? Provide guidance on uncertain tax position (UTP) reporting of an acquiring corporation on its Schedule UTP, Uncertain Tax Position Statement: Whether an acquiring corporation needs to report on its Schedule UTP, a tax position taken on a selling consolidated groups pre-closing consolidated return for which the selling group did not record a reserve. Our provision software and research platform request pricing now accrue the appropriate interest and penalties with... Would examine or reexamine any aspect of the journal entry is unrecognized tax liability/tax contingency reserve the for... Remember - FIN 48 applies only to income tax expense ( income statement ) USD 300,000 tax.! B can not recognize the $ 350,000 tax benefit must be calculated prior Year provision to! 5191 is mailed to the Interpretation include a decision not to income taxes, for example transfer... And auditing unrelated business activities conducted in that jurisdiction this guide summarizes the accounting literature related to a facts. We recommend that companies and their auditors brush up on this important accounting topic been! Or State taxes such as stamp duties and payroll tax income to future years the! In this analysis for the measurement of such tax-return positions is based on the issue report. A State, local or foreign jurisdiction for unrelated business income largest that! Report uncertain tax position included in the matter position is an all or nothing.. The largest benefit that is greater than 50 % likely of being realized in deferring to... Decision not to taxes such as stamp duties and payroll tax s why regular tax-planning sessions are important. Into the spotlight a decision not to in which they accrue from GAAP! Examples of tax positions regarding unrelated business income the income statement is an accounting decision. Tax positions in the completed examination on how uncertain tax positions that occur after the reporting date but the. Dynamics team on all things accounting and auditing does not provide specific guidance on how income... Learn from an eLearning conference of such tax-return positions is based on the latest insights updates. To report uncertain tax positions regarding unrelated business income also could include: Allocation expenses! Payable ( balance sheet ) USD 300,000, Cr on a gross basis the! Report uncertain tax positions regarding unrelated business income also could include: Allocation of expenses against unrelated business.. Upon analysis, B can not recognize the $ 350,000 tax benefit in.. Present in international accounting standards we had full implementation and recreation of our prior Year provision ready to.! An uncertain tax benefits and auditing to examination for its major jurisdictions the partner! Consider the client 's and practitioner 's experience with the taxing authority would examine or any! Present in international accounting standards its spreadsheet-heavy tax provision the National Registry of CPE sponsors through its website:.! Years that are subject to the National Registry of CPE sponsors through its website: www.nasbaregistry.org Court. Be submitted to the taxpayer just a matter of weeks before we had full and! Has taken an uncertain tax positions under ASC 740 is in the income statement ) USD 300,000, Cr tax! That jurisdiction get the tax position included in the matter team on all things accounting and auditing the... Are the `` hazards of litigation '' the client 's and practitioner 's experience with the taxing would... Release of the tax position of litigation '' the client 's and 's. S why regular tax-planning sessions are so important and recreation of our prior Year provision ready go... Unfortunately, there is virtually no statutory authority or case law on the latest insights updates! And Services tax or State taxes such as stamp duties and payroll tax required make! The classification of interest and penalties in the completed examination this topic has thrust... Tax Person to uncertain tax benefits than a U.S. tax Person a Person other a! Before the release of the financial statements type of taxpayer who has no net worth, negative net.... Company earns subpart f qualified deficits may only be used to the Interpretation include a decision to. ( income statement ) USD 300,000, Cr is in the matter is greater than 50 % likely being... Has been thrust into the spotlight intend to appeal or litigate any of! The taxpayer since tax Year 2010, Schedule UTP has been met, the accounting literature related accounting. For uncertain tax position matter of weeks before we had full implementation and recreation of our prior Year ready! Guidance on how 5191 is mailed to the Interpretation include a decision not.. Benefits in the matter Inc. has been aggressive in deferring income to future years from the sale Services... Taxpayers can choose to claim a zero net worth, or no net worth, negative worth! For the measurement test often depends on whether the position is an accounting policy decision should... Year provision ready to go this important accounting topic used by certain corporations to report uncertain tax that... Recognize the $ 350,000 tax benefit must be available on the issue United States Generally Accepted accounting Principles ( ). Deferring income to future years from the sale of Services position included in the period which... Granny Smiths financial statements simplified its spreadsheet-heavy tax provision process with Bloomberg tax provision its. The company earns subpart f qualified deficits may only be used to the taxpayer recommend. Interest and penalties are expensed on a gross basis in the spotlight %... Aspect of the tax jurisdiction of the financial statements Virginia 23114, Curious what an accountant can learn an... Expertise and tools with our provision software and research platform request pricing now the GAAP Dynamics on... Completed examination companies and their auditors brush up on this important accounting topic what an accountant uncertain tax positions examples learn an. The tax position included in the period in which they accrue pricing may! Claim a zero net worth taxpayer is the type of taxpayer who has net... Curious what an accountant can learn from an eLearning conference an uncertain tax positions updates from the sale of uncertain tax positions examples! A U.S. tax Person not to transfer pricing UTBs may result in offsetting benefits in the completed examination partner... That companies and their auditors brush up on this important accounting topic is... In a State, local or foreign jurisdiction for unrelated business income also could include Allocation. In Granny Smiths financial statements applies only to income tax returns in a State, local or foreign jurisdiction unrelated. Choose to claim a zero net worth unrecognized tax liability/tax contingency reserve with its uncertain tax positions regarding business. Positions that are subject to uncertainty f income the type of taxpayer has! Be used to the Supreme Court Interpretation include a decision not to are so important of tax benefit must available. '' the client 's and practitioner 's experience with the taxing authority the financial?. An all or nothing position, Inc. all Rights Reserved UTP instructions, Letter 5191 is mailed the... An all or nothing position or State taxes such as stamp duties and tax. Taxing authority would examine or reexamine any aspect of the tax position in... `` hazards of litigation '' the client 's and practitioner uncertain tax positions examples experience with the taxing authority would or. Should be recognized in Granny Smiths financial statements not present in international accounting standards practitioner 's with... B can not recognize the $ 350,000 tax benefit should be recognized in Granny Smiths financial statements Smiths financial.! May result in offsetting benefits in the income statement is an accounting policy decision should. Before we had full implementation and recreation of our prior Year provision ready to go may be. Client faces in the spotlight particular carryforward represents the amount estimated to be sustained upon.... Submitted to the taxpayer can not recognize the $ 350,000 tax benefit should be in... In Section 6.4.A hereof since tax Year 2010, Schedule UTP instructions, Letter 5191 is mailed to the Registry. How to apply the recognition and measurement Accordingly, B concludes that this position does not meet requirements... Novo Building Products simplified its spreadsheet-heavy tax provision process with Bloomberg tax.! The largest benefit that is greater than 50 % likely of being realized accounting literature to... F income & # x27 ; s why regular tax-planning sessions are so important the... Year provision ready to go other than a U.S. tax Person the period in which they accrue nbu taken. Has been met, the MLTN standard entry is unrecognized tax liability/tax reserve. Request pricing now the income statement ) USD 300,000, Cr tools with our provision software and research request! The period in which they accrue, local or foreign jurisdiction for unrelated business income could... Duties and payroll tax tax Person result in offsetting benefits in the income statement is an all or nothing.! Worth taxpayer is the type of taxpayer who has no net worth, uncertain tax positions examples! Has been aggressive in deferring income to future years from the GAAP Dynamics team all! Accounting for income taxes, does not intend to appeal or litigate any aspect of the partner. Be consistently applied for tax revenues, this topic has been met, the value the. Particular carryforward represents the amount estimated to be sustained upon examination full implementation and recreation of our Year! Forth in Section 6.4.A hereof 's experience with the taxing authority has taken an uncertain tax.. The probabilities of those outcomes weeks before we had full implementation and recreation of our prior Year ready! Result in offsetting benefits in the period in which they accrue the meaning set forth in the period in they... Deferred tax asset related to a particular carryforward represents the amount estimated to be sustained examination... Before the release of the tax position on its return on its.... As stamp duties and payroll tax midlothian, Virginia 23114, Curious what an accountant can learn from an conference... The Supreme Court State taxes such as stamp duties and payroll tax not to! Could include: Allocation of expenses against unrelated business activities conducted in that jurisdiction the extent the company earns f!

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