The Informativeness of FIN 48 ‘Look-Forward’ Disclosures

FASB Interpretation No. 48 (FIN 48) requires firms to disclose a forecast of significant changes in unrecognized tax benefits (UTBs) that are reasonably possible to occur within 12 months of the reporting date. According to paragraph 21(d), the “look-forward” disclosure, a firm must disclose either an estimate of the range of the change or state that an estimate cannot be made. Prior to the adoption of FIN 48, the willingness of firms to provide a meaningful estimate was debated because of the potential use of the information by tax authorities. We compare firms' predictions of expected UTB changes to their subsequently reported changes and find that firms with relatively low cash effective tax rates or involved in a tax dispute are more likely to provide a disclosure that states that a change is possible, but no forecast of the change is provided. This evidence is consistent with firms being reluctant to disclose expected reserve releases related to audit settlements or impending statute lapses. On the other hand, for those firms that do provide a forecast, our forecast accuracy analysis reveals significant understatement and overstatement errors, which suggests task difficulty rather than strategic understatement of the anticipated changes in tax reserves