Answer all the questions

Case 15-9c: Settled or Not Settled Page 1 Case 15-9 Settled or Not Settled Fact Pattern 1 3D Printing Inc. (3D Printing), a calendar-year-end company, has multiple uncertain tax positions (UTPs) related to its 2010 federal tax return. Some UTPs met the more-likely- than-not recognition threshold on the basis of 3D Printing's initial assessment while others did not. During 2012, the IRS audited the 2010 tax return. During Q3 2012, the examining agents verbally indicated the preliminary conclusion on certain UTPs, and the IRS and 3D Printing formalized their agreement on these UTPs by signing IRS Form 906, "Closing Agreement on Final Determination Covering Specific Matters," in Q4 2012. Subsequently, in Q1 2013, the IRS completed its examination of the 2010 tax return whereby the IRS and 3D Printing agreed to the final closing agreement. 3D Printing does not intend to appeal or litigate any aspects of the examined UTPs, and it is remote that the IRS would examine or reexamine any aspects of the 2010 federal tax return. Refer to the table below for further facts on each of the UTPs. Amount of Tax Benefit Recognized Met in the Verbally Listed on Recognition Financial Specifically Communicated Q4 Form Benefit Threshold? Statements Examined? in Q3? 906? Sustained UTP 1 No 0% Yes Yes Yes 80% UTP 2 No 0% No No No 100% UTP 3 No 0% Yes No Yes 0% UTP 4 Yes 65% Yes Yes Yes 50% UTP 5 Yes 70% No No No 100% UTP 6 Yes 60% Yes No Yes 0% Required: 1. For each tax position taken on its 2010 federal tax return: a. When can 3D Printing assert an "effective settlement"? b. When should 3D Printing adjust previously recognized amounts in the financial statements, if any? 2. Does 3D Printing have a basis to change its assessment of similar tax positions taken in other periods if it concludes it meets the effective settlement conditions related to the UTPs included in its 2010 tax return? 3. If 3D Printing were to report under IFRSs, what are the main differences in accounting for uncertainty in income taxes it would encounter? Copyright 2013 Deloitte Development LLC All Rights Reserved