FAS 109 and ASC 740: Deferred Taxes, Valuation Allowance, and Disclosures

ASC 740, the GAAP standard on accounting for income taxes, requires U.S. companies to book two things in their financial statements: the tax owed on this year’s return, and the future tax consequences of every difference between the GAAP balance sheet and the tax basis of those same items. It originated as FASB Statement No. 109 in 1992 and now lives in the FASB codification, and it drives entries that touch almost every line of a public company’s financials.

Why Book Income and Taxable Income Differ

GAAP and the Internal Revenue Code answer different questions. GAAP tries to show investors what happened economically; the tax code raises revenue and steers behavior through incentives. A company running both sets of books will almost always report a different “book income” on its income statement than the “taxable income” it puts on its return.1Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Temporary Differences

ASC 740 sorts the gap into two categories, and the category dictates the accounting.

Permanent Differences

A permanent difference is an item that counts toward one figure and is forever excluded from the other. Interest on tax-exempt municipal bonds hits book income but is never taxed. Some entertainment expenses reduce book income but can never be deducted. Permanent differences move the current effective tax rate but produce no future tax consequences and no deferred taxes.2Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Permanent Differences

Temporary Differences

Temporary differences are the engine of ASC 740. They exist when an asset or liability carries one amount on the GAAP balance sheet and a different tax basis. The standard assumes every asset eventually turns into cash and every liability eventually settles, so any gap between the two bases will reverse in some future year and generate a taxable or deductible amount then.3Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Objectives of ASC 740 That future consequence is what gets recorded as a deferred tax asset or liability.

Deferred Tax Liabilities and Deferred Tax Assets

ASC 740 uses a balance sheet approach. Instead of tracking timing differences through the income statement, the company compares the GAAP carrying amount of every asset and liability to its tax basis. Where they differ, a deferred tax liability or deferred tax asset captures the future tax effect.3Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Objectives of ASC 740

Deferred Tax Liabilities

A deferred tax liability (DTL) is a future tax bill the company has already earned. It arises when current tax is lower than book income would suggest. Depreciation is the classic example. A company might take accelerated depreciation on the return while reporting straight-line on its income statement. Tax basis drops faster than book basis, so tax deductions are larger now and smaller later. When the asset is sold or fully depreciated, future taxable income will exceed book income, and the DTL is that coming bill.

Revenue timing can produce DTLs too. Recognizing revenue for book purposes before it becomes taxable (percentage-of-completion accounting is one route) pushes book income above taxable income now, with the reverse coming later.

Deferred Tax Assets

A deferred tax asset (DTA) is the mirror. Current tax runs higher than book income would suggest, so the company has essentially prepaid tax it will recover through future deductions. Warranty reserves are a standard case: the expense hits the income statement at sale, but the deduction waits until the claim is paid.

DTAs also come from net operating loss (NOL) carryforwards and unused tax credits.3Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Objectives of ASC 740 Under current federal law, NOLs arising after 2017 carry forward indefinitely but can offset only 80% of taxable income in any single year. That cap matters for ASC 740 because it limits how quickly the DTA can actually reduce a future period’s tax.

The Valuation Allowance

Booking a DTA is a claim that the company will generate enough future taxable income to use the deduction. If that’s doubtful, ASC 740 requires a valuation allowance, a contra-asset that writes the DTA down to what the company actually expects to realize. The threshold is “more likely than not,” meaning greater than a 50% chance that some or all of the DTA will go unused, and it must be assessed separately for each tax jurisdiction.4PwC Viewpoint. Recognition of Benefits From Uncertain Tax Positions

The company weighs all available evidence. ASC 740 identifies four sources of taxable income that can support realization of a DTA:5Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Sources of Taxable Income

  • Reversals of existing DTLs, which generate taxable income that can absorb deductible temporary differences.
  • Future taxable income projected apart from reversing temporary differences, supported by a profitability track record or contracted revenue.
  • Carryback to a profitable prior year where the tax law allows it, which is highly objective evidence because it produces a refund.
  • Prudent and feasible tax-planning strategies the company could take to accelerate income or change its character to use expiring carryforwards.

Cumulative losses in recent years cut the other way. The codification calls this “a significant piece of negative evidence that is difficult to overcome.”6Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Basic Principles of Valuation Allowances In practice, companies look at a three-year window; cumulative pretax losses across that window create a strong presumption of a full valuation allowance, and overcoming it takes objectively verifiable positive evidence rather than management forecasts.

Changes to the allowance flow through current-period income tax expense. Setting one up increases the provision; releasing one decreases it. Because the swing can be large, these movements draw heavy scrutiny.

Uncertain Tax Positions

Companies routinely take return positions a taxing authority might challenge. ASC 740 lays out a two-step test for how much of the claimed benefit can appear in the financial statements.

Recognition

A benefit can be recognized only if it is more likely than not to be sustained on examination based purely on technical merits. The company must assume the taxing authority knows all relevant facts and will pursue the dispute to the highest available court. Whether the position will actually be audited is irrelevant; the analysis is about legal strength, not detection odds.4PwC Viewpoint. Recognition of Benefits From Uncertain Tax Positions A position that fails the threshold produces no recognized benefit; the whole amount sits as a liability for unrecognized tax benefits.

Measurement

Positions that clear recognition move to measurement. The company recognizes the largest amount of benefit with a cumulative probability greater than 50% of being realized upon settlement.7Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Uncertain Tax Positions Take a $100 deduction where management estimates a 40% chance of allowing the full amount, a 40% chance of allowing $50, and a 20% chance of nothing. Cumulative probability of at least some benefit is 80%, so recognition is met. The $50 outcome has an 80% cumulative probability (40% + 40%), so the company recognizes a $50 benefit and records the remaining $50 as an unrecognized tax benefit liability.

Classification, Interest, and Penalties

Unrecognized tax benefit liabilities are noncurrent unless the company expects a cash payment within one year or the operating cycle.8PwC Viewpoint. Presentation and Disclosure of Uncertain Tax Positions If the statute of limitations is expected to expire without cash changing hands, the liability stays noncurrent even close to expiration.

Companies must accrue interest and penalties on unrecognized tax benefits. ASC 740 allows an accounting policy election on presentation: classify them as income tax expense, or as a separate line such as interest expense. The choice must be applied consistently and disclosed.

Public companies also present a tabular reconciliation of the UTB balance from the beginning to the end of each annual reporting period, breaking out increases from current-year positions, increases and decreases from prior-year positions, settlements, and reductions from statute expirations.9Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – UTB Related Disclosures

When Tax Rates Change

Deferred tax balances are measured at the enacted rate expected to apply when the temporary difference reverses. When a jurisdiction enacts a new rate, every existing DTA and DTL there is remeasured immediately, and the entire adjustment flows through income tax expense in the period of enactment. It is not spread over time. A rate cut shrinks both DTLs and DTAs; a rate increase inflates them. Companies with large deferred balances saw enormous income statement swings when the federal corporate rate dropped from 35% to 21% under the Tax Cuts and Jobs Act.

The Total Tax Provision and Where It Lands

The income statement provision has two components: current tax expense and deferred tax expense or benefit.3Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Objectives of ASC 740

Current tax is what the return produces: the enacted rate applied to taxable income, owed or refundable. Permanent differences affect it directly because they change taxable income with no future offset.

Deferred tax captures the net movement in all deferred accounts during the period, including any change in valuation allowance. If DTLs grew faster than DTAs, deferred expense rises; if DTAs grew or a valuation allowance was released, deferred expense falls. Together the two components make the income statement reflect the period’s full tax picture, not just this year’s check to the IRS.

Intraperiod Allocation

ASC 740 also dictates where tax expense lands within the statements. Intraperiod tax allocation splits the provision among continuing operations, discontinued operations, other comprehensive income, and equity.10PwC Viewpoint. Intraperiod Allocation – The Basic Model Continuing operations gets first priority: its tax is computed independently, as if it were the only source of income. The remainder is allocated among the other items. With just one other item, it absorbs the whole remainder; with two or more, the remainder is split proportionally based on each item’s individual tax effect.

Some tax effects skip the income statement entirely and go to other comprehensive income or equity: unrealized gains and losses on available-for-sale securities, foreign currency translation adjustments, and tax effects of transactions among shareholders are typical examples.

Balance Sheet Presentation

All DTAs and DTLs are noncurrent, regardless of when the underlying difference is expected to reverse. Within the same tax-paying entity and the same jurisdiction, DTAs, DTLs, and any related valuation allowance net into a single noncurrent amount. Netting across jurisdictions is prohibited; a federal DTA cannot offset a state or foreign DTL.11Deloitte Accounting Research Tool. Deloitte’s Roadmap Income Taxes – Statement of Financial Position Classification

Disclosures, Including the New ASU 2023-09 Requirements

Public companies have long been required to disclose a rate reconciliation between the statutory federal rate (21% for U.S. corporations) and the company’s effective tax rate, showing why actual tax expense differs from a straight 21%: permanent differences, state taxes, foreign rate differentials, valuation allowance changes, and credits each appear as separate reconciling items.12Ernst & Young (EY). FASB Requires Entities to Provide Additional Income Tax Disclosures

ASU 2023-09

ASU 2023-09 substantially expands the required disclosures. It is effective for public business entities in fiscal years beginning after December 15, 2024, which means calendar-year 2025 financials and beyond; other entities apply it one year later, for annual periods beginning after December 15, 2025.13FASB. Effective Dates

The rate reconciliation now has to disaggregate into eight standard categories, reported in both percentages and dollars:14Deloitte Accounting Research Tool. Income Tax Disclosure Considerations Related to the Adoption of ASU 2023-09

  • State and local income taxes, net of the federal tax effect.
  • Foreign tax effects from applying foreign rates.
  • Effects of tax law or rate changes enacted during the period.
  • Cross-border tax law effects, such as GILTI, BEAT, or Pillar Two adjustments.
  • Tax credits, including research and energy credits.
  • Valuation allowance increases or releases flowing through the provision.
  • Nontaxable or nondeductible items, meaning permanent differences.
  • Changes in unrecognized tax benefits.

Several of those categories must be broken out further whenever a single reconciling item exceeds a 5% materiality threshold, defined as 5% of pretax income multiplied by the statutory rate. For a U.S. company, that works out to roughly 1.05% of pretax income (21% Ă— 5%), and any item above that has to be identified and described by nature.14Deloitte Accounting Research Tool. Income Tax Disclosure Considerations Related to the Adoption of ASU 2023-09

ASU 2023-09 also requires disclosure of income taxes paid net of refunds, broken out by federal, state, and foreign jurisdictions, with any individual jurisdiction exceeding 5% of the total identified separately.

Quarterly Reporting Under ASC 740-270

ASC 740 applies at interim dates too. Under ASC 740-270, each quarter the company estimates an annual effective tax rate (AETR) by forecasting full-year ordinary income and its tax, then applies that rate to year-to-date results. Quarterly tax expense is the year-to-date amount minus what was booked in earlier quarters.

Items that are unusual, infrequent, or unrelated to ordinary income are “discrete” and recorded entirely in the quarter they occur rather than smoothed through the AETR. A mid-year tax law change, a valuation allowance release tied to a specific event, and the settlement of an uncertain tax position are all discrete. The AETR estimate is where most companies struggle, because a small revision to the full-year forecast can move quarterly tax expense sharply.