- List the disclosures required of all entities and those required only of PBEs
- Apply the 5 percent threshold to income taxes paid by jurisdiction
- Identify disclosures ASU 2023-09 removed
- Tie the income tax note to the provision workpapers
Disclosures for all entities
ASU 2023-09 rewrote much of ASC 740-10-50. For annual periods, all entities disclose:
- Components of income tax expense attributable to continuing operations (ASC 740-10-50-9): current, deferred, investment tax credits, benefits of loss carryforwards, effects of enacted rate changes, and changes in beginning-of-year valuation allowances, among others.
- Intraperiod amounts (50-10): tax allocated to continuing operations and the amounts allocated to other items.
- Pretax income from continuing operations split between domestic and foreign (50-10A).
- Income tax expense from continuing operations split among federal (national), state and foreign (50-10B). Tax imposed by the country of domicile on foreign earnings goes in the domicile amount.
- Income taxes paid, net of refunds, split among federal (national), state and foreign (50-22), and by each individual jurisdiction where taxes paid are 5 percent or more of total taxes paid, net of refunds (50-23).
- Carryforwards: Statement 109 paragraph 48 requires the amounts and expiration dates of operating loss and tax credit carryforwards.
- Unrecognized tax benefit items (50-15): the total interest and penalties recognized in the statement of operations and in the balance sheet, and a description of tax years that remain subject to examination by major jurisdictions.
- Rate reconciliation: numerical for PBEs, qualitative for other entities, as covered in the rate reconciliation lesson.
Disclosures only PBEs give
- Tax effects of temporary differences (50-6): the approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax assets and liabilities, before valuation allowances. Other entities disclose the types of significant temporary differences and carryforwards but may omit the tax effects (50-8).
- Unrecognized tax benefit rollforward (50-15A): a tabular reconciliation of the beginning and ending balance, showing gross increases and decreases for prior-period and current-period positions, settlements and statute lapses, plus the total that would affect the effective rate if recognized.
- Tabular rate reconciliation with the eight categories and the state jurisdiction description.
What ASU 2023-09 removed
- The disclosure of the nature and estimate of the range of the reasonably possible change in unrecognized tax benefits in the next 12 months (or a statement that an estimate cannot be made).
- The cumulative amount of each type of temporary difference when a deferred tax liability is not recognized under the subsidiary and joint venture exceptions.
ASU 2023-09 also replaced the term public entity with public business entity throughout Topic 740.
Other required items
- An accounting policy for classifying interest and penalties (Interpretation 48 paragraph 19 requires a consistent election and paragraph 20 requires the policy to be disclosed).
- The policy for taxes on CFC inclusions, if applicable (see the cross-border lesson).
- Members of a consolidated return group that issue separate statements disclose the amounts of current and deferred tax expense and intercompany tax balances (Statement 109 paragraph 49).
Effective dates
PBEs apply ASU 2023-09 for annual periods beginning after December 15, 2024; all other entities for annual periods beginning after December 15, 2025. Transition is prospective with retrospective application permitted.
Audit focus
Use a disclosure checklist and tie each number to the provision: components to the current and deferred computation, taxes paid to the payable and prepaid rollforward and cash records, and the unrecognized tax benefit table to the rollforward. Taxes paid is a cash number; do not derive it from expense.
Taxes paid disclosure for Copperline Foods, Inc.
Copperline Foods paid income taxes, net of refunds, of $3,000,000 during the year:
- U.S. federal: $1,800,000
- State: California $400,000, New York $160,000, all other states $140,000 combined (no single state above $50,000)
- Foreign: United Kingdom $350,000, all other countries $150,000 combined (no single country above $60,000)
Threshold: 3,000,000 x 5% = $150,000.
Disaggregation by level (50-22):
- Federal: $1,800,000
- State: 400,000 + 160,000 + 140,000 = $700,000
- Foreign: 350,000 + 150,000 = $500,000
- Total: 1,800,000 + 700,000 + 500,000 = $3,000,000
Individual jurisdictions at or above $150,000 (50-23): U.S. federal ($1,800,000), California ($400,000), United Kingdom ($350,000) and New York ($160,000).
New York is disclosed even though it is close to the line, because $160,000 is above $150,000. The other states and countries are each below the threshold, so they stay in the aggregate amounts. If New York had paid $149,000, it would drop into the state aggregate.
Self-check
Answer each question before you open the answer.
What threshold determines whether income taxes paid to a single jurisdiction must be disclosed separately?
Show answer
Taxes paid, net of refunds, to that jurisdiction equal to or greater than 5 percent of total income taxes paid, net of refunds (ASC 740-10-50-23).
Does a private company have to present the tabular rollforward of unrecognized tax benefits?
Show answer
No. ASC 740-10-50-15A applies to public business entities. All entities disclose interest and penalties recognized and the tax years open to examination under 50-15.
Which unrecognized tax benefit disclosure did ASU 2023-09 eliminate for all entities?
Show answer
The disclosure of the nature and estimate of the range of the reasonably possible change in unrecognized tax benefits within 12 months, or a statement that an estimate cannot be made.
Why should the auditor not test income taxes paid by comparing it with current tax expense?
Show answer
Taxes paid is a cash amount that includes estimated payments, prior-year balances and refunds, and differs from current expense by timing. It should be tied to cash records and the payable and prepaid rollforward.
Use it on the file
- TemplateDisclosure Checklist: Income Taxes (ASC 740)
- StandardASU 2023-09: ASU 2023-09 Income Tax Disclosures: Rate Reconciliation and Taxes Paid
- TemplateIncome Tax Payable and Prepaid Rollforward (Excel)
- GuideASU 2023-09 Income Tax Disclosures: Rate Reconciliation, Income Taxes Paid and What the Auditor Ties Out
Sources
- FASB, ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures
- FASB, Statement No. 109, Accounting for Income Taxes (original pronouncement, now ASC 740)
- FASB, Interpretation No. 48, Accounting for Uncertainty in Income Taxes (now ASC 740-10)
Standards are paraphrased from the primary sources listed above; read the source before relying on a requirement. This lesson is training material, not professional advice. Report an error