CY » Topics » Unrecognized Tax Benefits

This excerpt taken from the CY 10-Q filed May 8, 2009.

Unrecognized Tax Benefits

As of March 29, 2009 and December 28, 2008, the amounts of unrecognized tax benefits recorded in the Condensed Consolidated Balance Sheet that, if recognized, would affect our effective tax rate totaled approximately $20.8 million and $20.4 million, respectively.

Management believes events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:

 

   

completion of examinations by foreign taxing authorities; and

 

   

expiration of statute of limitations on the Company’s tax returns.

The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses our tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which we do business.

These excerpts taken from the CY 10-K filed Feb 26, 2009.

Unrecognized Tax Benefits

The Company adopted the provisions of FASB Interpretation No. 48, “Accounting for Uncertainty in Income Taxes – an interpretation of FASB Statement No. 109” (“FIN 48”), on January 1, 2007. As a result of the implementation of FIN 48, the Company recognized an increase in the liability for unrecognized tax benefits of $3.1 million in fiscal 2007 and a corresponding increase in “Accumulated deficit” in the Consolidated Balance Sheet. A reconciliation of unrecognized tax benefits is as follows:

 

(In thousands)

      

Unrecognized tax benefits as of January 1, 2007

   $ 38,893  

Increase based on tax positions related to current year

     4,760  

Increase based on tax positions related to prior years

     3,154  
        

Unrecognized tax benefits as of December 30, 2007

     46,807  

Decrease based on tax positions related to current year

     (14,251 )

Decrease related to settlements with taxing authorities

     (10,511 )
        

Unrecognized tax benefits as of December 28, 2008

   $ 22,045  
        

As of December 28, 2008 and December 30, 2007, the amounts of unrecognized tax benefits that, if recognized, would affect the Company’s effective tax rate totaled $20.4 million and $42.0 million, respectively.

Management believes events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:

 

   

completion of examinations by foreign taxing authorities; and

 

   

expiration of statue of limitations on the Company’s tax returns.

The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company’s tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business.

Unrecognized Tax Benefits

The Company adopted the provisions of FASB Interpretation No. 48, “Accounting for Uncertainty in Income Taxes – an interpretation of FASB Statement No. 109” (“FIN 48”), on January 1, 2007. As a result of the implementation of FIN 48, the Company recognized an increase in the liability for unrecognized tax benefits of $3.1 million in fiscal 2007 and a corresponding increase in “Accumulated deficit” in the Consolidated Balance Sheet. A reconciliation of unrecognized tax benefits is as follows:

 

(In thousands)

      

Unrecognized tax benefits as of January 1, 2007

   $ 38,893  

Increase based on tax positions related to current year

     4,760  

Increase based on tax positions related to prior years

     3,154  
        

Unrecognized tax benefits as of December 30, 2007

     46,807  

Decrease based on tax positions related to current year

     (14,251 )

Decrease related to settlements with taxing authorities

     (10,511 )
        

Unrecognized tax benefits as of December 28, 2008

   $ 22,045  
        

As of December 28, 2008 and December 30, 2007, the amounts of unrecognized tax benefits that, if recognized, would affect the Company’s effective tax rate totaled $20.4 million and $42.0 million, respectively.

Management believes events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:

 

   

completion of examinations by foreign taxing authorities; and

 

   

expiration of statue of limitations on the Company’s tax returns.

The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company’s tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business.

This excerpt taken from the CY 10-Q filed Nov 7, 2008.

Unrecognized Tax Benefits

The following table presents a reconciliation of the Company’s unrecognized tax benefits:

 

(In thousands)

      

Unrecognized tax benefits, as of December 30, 2007

   $ 50,983  

Increase based on tax positions related to current year

     3,753  

Decrease based on tax positions related to current year

     (14,096 )

Decrease related to settlements with taxing authorities

     (11,212 )
        

Unrecognized tax benefits, as of September 28, 2008

   $ 29,428  
        

As of September 28, 2008 and December 30, 2007, the amounts of unrecognized tax benefits that, if recognized, would affect the effective tax rate totaled $22.6 million and $45.9 million, respectively.

Management believes events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:

 

   

completion of examinations by foreign taxing authorities; and

 

   

expiration of statue of limitations on the Company’s tax returns.

The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company’s tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business.

This excerpt taken from the CY 10-Q filed Aug 8, 2008.

Unrecognized Tax Benefits

The following table presents a reconciliation of the Company’s unrecognized tax benefits:

 

(In thousands)

      

Unrecognized tax benefits, as of December 30, 2007

   $ 50,983  

Increase based on tax positions related to current year

     2,246  

Decrease based on tax positions related to current year

     (14,096 )

Decrease related to settlements with taxing authorities

     (7,323 )
        

Unrecognized tax benefits, as of June 29, 2008

   $ 31,810  
        

As of June 29, 2008 and December 30, 2007, the amounts of unrecognized tax benefits that, if recognized, would affect the effective tax rate totaled $26.1 million and $45.9 million, respectively.

Management believes events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:

 

   

completion of examinations by foreign taxing authorities; and

 

   

expiration of statue of limitations on the Company’s tax returns.

The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company’s tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business.

This excerpt taken from the CY 10-Q filed May 9, 2008.

Unrecognized Tax Benefits

 

As of December 30, 2007, the total amount of unrecognized tax benefits recorded in the Condensed Consolidated Balance Sheet was approximately $51.0 million, of which $45.9 million would affect the Company’s effective tax rate if recognized.  The Company recorded an additional 0.6 million of unrecognized tax benefits during the first quarter of fiscal 2008.

 

24



 

Management believes events that could occur in the next 12 months to cause a material change in unrecognized tax benefits include, but are not limited to, the following:

 

·              completion of examinations of the Company’s tax returns by the United States or foreign taxing authorities; and

·              expiration of statue of limitations on the Company’s tax returns.

 

The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company’s tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business.

 

These excerpts taken from the CY 10-K filed Mar 3, 2008.

Unrecognized Tax Benefits

        The Company adopted the provisions of FIN 48 on January 1, 2007. As a result of the implementation of FIN 48, the Company recognized an increase in the liability for unrecognized tax benefits of $3.1 million and a corresponding increase in "Accumulated deficit" in the Consolidated Balance Sheet. A reconciliation of unrecognized tax benefits is as follows:

(In thousands)

   
Unrecognized tax benefits, as of January 1, 2007   $ 40,013
Additions based on tax positions related to current year     4,473
Additions based on tax positions related to prior years     6,497
   
Unrecognized tax benefits, as of December 30, 2007   $ 50,983
   

        Included in the unrecognized tax benefit balance as of December 30, 2007 were $45.9 million that would affect the Company's effective tax rate if recognized.

        Management believes that events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:

    commencement, continuation or completion of examinations of the Company's tax returns by the United States or foreign tax authorities; and

    expiration of statute of limitations on the Company's tax returns.

        The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company's tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business. Management does not anticipate material changes in the unrecognized tax benefits within the next 12 months.

Unrecognized Tax Benefits



        The Company adopted the provisions of FIN 48 on January 1, 2007. As a result of the implementation of FIN 48, the Company recognized an
increase in the liability for unrecognized tax benefits of
$3.1 million and a corresponding increase in "Accumulated deficit" in the Consolidated Balance Sheet. A reconciliation of unrecognized tax benefits is as follows:












































(In thousands)

  
Unrecognized tax benefits, as of January 1, 2007 $40,013
Additions based on tax positions related to current year  4,473
Additions based on tax positions related to prior years  6,497
  
Unrecognized tax benefits, as of December 30, 2007 $50,983
  




        Included
in the unrecognized tax benefit balance as of December 30, 2007 were $45.9 million that would affect the Company's effective tax rate if recognized.



        Management
believes that events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:





    commencement,
    continuation or completion of examinations of the Company's tax returns by the United States or foreign tax authorities; and


    expiration
    of statute of limitations on the Company's tax returns.



        The
calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company's tax
positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the
Company does business. Management does not anticipate material changes in the unrecognized tax benefits within the next 12 months.




This excerpt taken from the CY 10-Q filed Nov 9, 2007.

Unrecognized Tax Benefits

        The Company adopted the provisions of FIN 48 on January 1, 2007. As a result of the implementation of FIN 48, the Company recognized an increase in the liability for unrecognized tax benefits of $3.2 million and a corresponding increase in accumulated deficit. As of January 1, 2007, the total amount of unrecognized tax benefits was approximately $59.9 million, of which $37.2 million, if recognized, would affect the Company's effective tax rate and $22.7 million would result in an additional deferred tax asset that would be offset by a valuation allowance. The Company recorded FIN 48-related liabilities of $2.0 million and $5.5 million during the third quarter and first nine months

37



of fiscal 2007, respectively. Management believes that events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:

    completion of examinations of the Company's tax returns by the U.S. or foreign tax authorities; and
    expiration of statute of limitations on the Company's tax returns.

        The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company's tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business. Management does not anticipate material changes in the unrecognized tax benefits within the next 12 months.

This excerpt taken from the CY 10-Q filed Aug 10, 2007.

Unrecognized Tax Benefits

The Company adopted the provisions of FIN 48 on January 1, 2007. As a result of the implementation of FIN 48, the Company recognized an increase in the liability for unrecognized tax benefits of $3.2 million and a corresponding increase in accumulated deficit. As of January 1, 2007, the total amount of unrecognized tax benefits was approximately $59.9 million, of which $37.2 million, if recognized, would affect the Company’s effective tax rate and $22.7 million would result in an additional deferred tax asset that would be offset by a valuation allowance. We recorded FIN 48-related liabilities of $2.4 million and $2.7 million during the second quarter and first half of fiscal 2007, respectively. Management believes that events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:

 

   

completion of examinations of the Company’s tax returns by the U.S. or foreign tax authorities; and

 

   

expiration of statue of limitations on the Company’s tax returns.

The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company’s tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business. Management does not anticipate material changes in the unrecognized tax benefits within the next 12 months.

This excerpt taken from the CY 10-Q filed May 11, 2007.

Unrecognized Tax Benefits

The Company adopted the provisions of FIN 48 on January 1, 2007. As a result of the implementation of FIN 48, the Company recognized an increase in the liability for unrecognized tax benefits of $3.2 million and a corresponding increase in accumulated deficit. As of January 1, 2007, the total amount of unrecognized tax benefits was approximately $59.9 million, of which $37.2 million, if recognized, would affect the Company’s effective tax rate and $22.7 million would result in an additional deferred tax asset that would be offset by a valuation allowance. There have been no material changes to the amount of unrecognized tax benefits during the first quarter of fiscal 2007. Management believes that events that could occur in the next 12 months and cause a material change in unrecognized tax benefits include, but are not limited to, the following:

 

   

completion of examinations of the Company’s tax returns by the U.S. or foreign tax authorities; and

 

   

expiration of statue of limitations on the Company’s tax returns.

The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company’s tax positions in light of legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business. Management determined that an estimate of the range of reasonably possible material changes in the unrecognized tax benefits within the next 12 months cannot be made.

"Unrecognized Tax Benefits" elsewhere:

STMicroelectronics N.V. (STM)
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