Disclosure of open tax years is now only required for a nonpublic entity that has material unrecognized tax benefits
Disclosing which fiscal years are open to audit by tax authorities has been required for nonpublic companies for several years. An explicit requirement came into play with Technical Practice Aid 5250.15.
Effective March 2015 that TPA was deleted. The requirement now is based on a comment buried in the Basis for Conclusions of ASU 2009-06, which says disclosure of open tax years is only needed when there are material unrecognized tax benefits.
Impact of TPA 5250.15
That requirement has produced a standard comment on all nonpublic entity financial statements that looks something like this:
The entity files income tax returns with the U. S. and (state) governments. With few exceptions, the entity is no longer subject to U.S. federal and state income tax examinations by tax authorities for years before 20×1.
The AICPA has deleted TPA 5250.15. That type of comment will not be required unless the entity has material unrecognized tax benefits.
What changed?
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