What are the most challenging tax positions for corporate tax departments relating to FIN 48 compliance? The consensus was international tax positions when a group of Tax Executives Institute (TEI) members joined Thomson Tax & Accounting, a business segment of The Thomson Corporation (NYSE: TOC; TSX: TOC) to discuss the effect of the new requirements.

"Increasingly, tax executives face regulatory and compliance requirements and this is particularly challenging for any company with global operations. The best way for tax executives to handle a new area like FIN 48 is to make sure their staffs, including international staffs, are fully trained, and up to date on the latest guidance. This can be a complex process and FIN 48 is pushing companies to find ways to coordinate information," says Timothy McCormally, executive director, TEI.

Linda Scheffel, vice president and publisher, Research & Guidance at Thomson Tax & Accounting said, "In multinational corporations, for FIN 48 purposes, integration is necessary at several levels -- corporate and local, U.S. and non-U.S. -- financial reporting, tax, legal, and facts-and-circumstances expertise are all required simultaneously. The integration of so many functional areas and continued compliance challenges is multiplied for U.S. and non-U.S. tax and financial reporting staff when there are U.S. tax or financial reporting changes or when regulatory bodies make key changes -- like those that IRS seems poised to announce, and the proposed changes to SEC reporting related to GAAP reconciliation."

"For these reasons, the financial reporting group worked with the tax authors at Thomson Tax & Accounting to create value-added information, workflow tools, and checklists related to FIN 48 compliance using Checkpoint(R) when preparing the FIN 48 treatise -- FIN 48-Accounting for Uncertain Income Tax Provisions. For example, the checklist on FIN 48 compliance walks users through a review of international tax positions by creating a Checkpoint roadmap to monitor U.S. and international tax and financial reporting changes on Checkpoint."

While the TEI panel didn't specify which international issue posed the greatest difficulty, Scheffel commented that based on general SEC filings, transfer pricing issues already existed for many companies before FIN 48. In the International Taxes Weekly series on FIN 48, WG&L author Cym Lowell said that "Transfer pricing issues appear to be among the most difficult in the FIN 48 opinion context," and that "in the context of a company group's transfer pricing arrangements, the tax position in question is the financial reporting of any of the related-party transactions between the various members of the group."

Bijal Sheth, vice president, Strategic Marketing, Research & Guidance, Thomson Tax & Accounting agrees: "Thomson Tax & Accounting enables professionals to be more productive by creating integrated research tools and online training courses that not only provide all of the guidance needed but integrate that information in very practical ways.

By using an integrated online solution, like Thomson Tax & Accounting's Checkpoint, corporations can get practical guidance on FIN 48 compliance (FIN 48-Accounting for Uncertain Income Tax Positions (WG&L)), the ability to review the SEC filings of competitors and other similarly situated companies (SECPlus (WG&L)), and the integrated international library featuring products from WG&L, IBFD, BNA, RIA and so much more." To further increase productivity, added Sheth, professionals can use InSource(R) FIN48, which integrates Checkpoint's research and InSource workflow tools, to easily access everything they need to deal with FIN 48. As part of its complete FIN 48 solution, Thomson Tax & Accounting also offers CPE and training, both online and live seminars and conferences, to assist professionals as they implement FIN 48 requirements.

Sheth pointed out that new in the arsenal for international tax executives and new to Checkpoint is the "Accounting & Compliance Alert: Public Company Financial Management Update." This is a state-of-the-art daily news service from Thomson Tax & Accounting that will keep you fully informed about critical public company financial management issues. This news bureau combines breaking news from standard-setting agencies and organizations, including the SEC, NYSE, NASD, AICPA, PCAOB, FASB, IASB and the IRS, as well as the latest legislative and industry news with in-depth feature articles from industry leaders containing insights, analysis, and opinions on recent developments and emerging trends and Checkpoint functionality. Checkpoint is now the source for all of the information that tax and financial reporting executives and staff need to comply with FIN 48 and virtually every other international tax issue."

Whether through Checkpoint, the industry-leading online research platform, InSource FIN48, the most comprehensive FIN 48 software solution, or CrossBorder Solutions, the worldwide industry standard in transfer pricing compliance software, Thomson Tax & Accounting is regarded as the preeminent source of information and up-to-the-minute guidance, offering a wide range of integrated resources to manage the complex regulatory and compliance requirements of FIN 48.

TEI is the preeminent association of business tax executives in North America with 7,000 members representing 3,200 of the leading corporations in the United States, Canada, Europe, and Asia. TEI represents a cross-section of the business community, and is dedicated to developing and effectively implementing sound tax policy, promoting the uniform and equitable enforcement of the tax laws, and reducing the cost and burden of administration and compliance to the benefit of taxpayers and government alike. As a professional association, TEI is firmly committed to maintaining a tax system that works -- one that is administrable and with which taxpayers can comply in a cost-efficient manner.

Members of TEI are responsible for managing the tax affairs of their companies and must contend daily with the provisions of the tax law relating to the operation of business enterprises. The diversity and professional training of TEI's members enable it to bring a balanced and practical perspective to the issues raised by the FIN 48 rules.

The Thomson Corporation

The Thomson Corporation is a global leader in providing essential electronic workflow solutions to business and professional customers. With operational headquarters in Stamford, Conn., Thomson provides value-added information, software tools and applications to professionals in the fields of law, tax, accounting, financial services, scientific research and healthcare. The Corporation's common shares are listed on the New York and Toronto stock exchanges.

Thomson Tax & Accounting is a business segment of Thomson and a leading provider of technology and integrated information solutions to accounting, tax and corporate finance professionals in accounting firms, corporations, law firms and government. Thomson Tax & Accounting includes the Professional Software & Services, Corporate Software & Services, and Research & Guidance business groups.

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