FAR · Select transactions · 6 practice questions
ASC 740: Valuation Allowance vs. Uncertain Tax Positions
A valuation allowance tests whether a deferred tax asset can be used; uncertain tax position accounting tests technical support, then the amount recognized. Below, judge responses to a claimed tax benefit using the recognition and measurement rules.
Try one first
Hint
Separate three issues: measurement, realizability, and presentation. For a valuation allowance, focus on the most supportable source of taxable income.
Answer A. Under ASC 740, a deferred tax asset requires a valuation allowance if it is more likely than not that some portion will not be realized. One of the most persuasive sources of taxable income to support realization is the future reversal of existing taxable temporary differences in the same jurisdiction and periods. Given North's recent cumulative losses and that management's projections lack objectively verifiable support, the existence and timing of reversing taxable temporary differences should govern the realizability analysis.
Why not B: Tempting because future enacted rates affect measurement of deferred taxes, but a valuation allowance question concerns realizability (sources of taxable income), not the tax rate used to measure the deferred amounts.
Why not C: Future taxable income is a possible source of realization, but unsupported internal projections are weak evidence, especially when the company has recent cumulative losses, so projections do not govern the analysis here.
Why not D: Presentation/offsetting is a separate reporting issue; whether amounts may be presented net does not determine whether the deferred tax asset is realizable and thus whether a valuation allowance is needed.
What should you do?
The situation
Alder Co. claimed a $120,000 tax benefit on its return. It meets ASC 740's recognition threshold on technical merits, assuming examination with full knowledge. Possible sustained benefits are $120,000 (40%), $90,000 (20%), $60,000 (15%), $30,000 (15%), and $0 (10%). Management considers examination unlikely. Ignore interest and penalties. What should Alder report?
Recognize a $90,000 benefit and a $30,000 unrecognized tax benefit liability.
Best Cumulative probability reaches 60% at $90,000: 40% + 20%. The remaining $30,000 is unrecognized.
Recognize the full $120,000 benefit because recognition is met.
Wrong Passing recognition does not support the full amount. The $120,000 outcome has only a 40% probability.
Recognize a $79,500 benefit using probability-weighted expected value.
Wrong ASC 740 uses the cumulative-probability threshold, not a probability-weighted average.
Recognize a $60,000 benefit because cumulative probability reaches 75%.
Wrong The $60,000 level reaches 75%, but $90,000 is the largest benefit exceeding 50% cumulatively.
Recognize a $90,000 benefit and a $30,000 valuation allowance.
Wrong The $30,000 reflects technical uncertainty about a claimed benefit, not inability to realize a deferred tax asset.
Key points
- Remember: A valuation allowance tests DTA realizability; uncertain tax position accounting tests technical support before measuring the benefit.
- Cumulative losses outweigh unsupported forecasts; scheduled taxable reversals can support DTAs in the same jurisdiction when deductions can be used.
- Assess DTA realizability separately by tax jurisdiction and tax-paying component.
- For uncertain tax positions, ignore audit risk and accumulate outcome probabilities from the largest benefit downward.
How the exam traps you
- Using a valuation allowance for the unsupported portion of a claimed tax position. Use uncertain tax position accounting for technical uncertainty; use a valuation allowance for DTA realizability.
- Letting a low chance of examination justify recognizing the claimed benefit. Assume examination with full knowledge; assess technical merits before measuring the benefit.
- Choosing the most likely outcome or a probability-weighted average. Start with the largest benefit and add probabilities until the total exceeds 50%.
Question 2
| Tax Item | Amount |
|---|---|
| Benefit: 40% | $120,000 |
| Benefit: 20% | $90,000 |
| Benefit: 15% | $60,000 |
| Benefit: 15% | $30,000 |
| Benefit: 10% | $0 |
Hint
Treat this as two steps: confirm recognition is met, then sum probabilities from the largest benefit downward until cumulative probability exceeds 50%; the corresponding benefit amount is the recognized amount.
Answer B. ASC 740 uses a two-step model: recognition (more-likely-than-not) and measurement. Having met recognition, measurement is the largest amount of tax benefit that is greater than 50% likely to be realized on ultimate settlement. Cumulative probabilities from the largest outcome downward are: at least $120,000 = 40%; at least $90,000 = 40% + 20% = 60% (>50%); at least $60,000 = 75%; at least $30,000 = 90%. The largest amount with cumulative probability >50% is $90,000, so Alder recognizes $90,000 and records the remaining $30,000 as an unrecognized tax benefit liability.
Why not A: Tempting because recognition was met, but measurement requires the largest amount whose cumulative probability of realization exceeds 50%. The probability of realizing at least $120,000 is only 40% (the single $120,000 outcome), which is below the >50% threshold, so recognizing the full $120,000 is not supported.
Why not C: This choice reflects an overly conservative selection. Although the cumulative probability of at least $60,000 is 75% (40% + 20% + 15%), ASC 740 requires selecting the largest amount with cumulative probability >50%; here the largest such amount is $90,000 (cumulative 60%), so $60,000 understates the recognized benefit.
Why not D: Incorrect because ASC 740 permits recognition once the recognition threshold is met and measurement uses cumulative probabilities across outcomes rather than requiring a single outcome >50%. For example, the cumulative probability of at least $90,000 is 60% (40% + 20%), so some amount above $0 should be recognized.
Question 3
Hint
Distinguish the question of whether any benefit may be recognized at all (recognition) from how much benefit is recognized or preserved (measurement/realization).
Answer C. ASC 740 uses a two-step model: first determine recognition, then measure the amount. Recognition requires that an uncertain tax position be more likely than not (i.e., greater than 50%) to be sustained on its technical merits, assuming examination by the taxing authority with full knowledge of the relevant facts. Detection risk, settlement expectations, and available tax-planning strategies may affect measurement or realization analyses but do not set the recognition threshold.
Why not A: Tempting because low audit risk might seem to reduce exposure; however ASC 740's recognition test excludes detection risk and evaluates the position as if examined with full knowledge of the facts.
Why not B: Tempting because settlement expectations relate to how much benefit might be preserved in practice, but expected negotiation or settlement outcomes are measurement inputs after a position meets the recognition threshold, not the recognition test itself.
Why not D: Tempting because planning can affect realization or measurement of tax assets, but feasible tax-planning strategies do not determine whether an uncertain tax position satisfies ASC 740's recognition requirement.
Question 4
Hint
Separate the recognition test from the measurement rule. First ask whether any benefit can be recognized; then ask how ASC 740 tells you to measure the amount.
Answer D. ASC 740 separates recognition from measurement: after a position passes the recognition threshold, the amount recognized is measured as the largest tax benefit that is cumulatively more than 50% likely to be realized upon settlement. Applying Holt's outcome probabilities, the cumulative probability exceeds 50% at the $180,000 level, so the measurement rule would support recognizing $180,000. The governing principle is therefore the cumulative-greater-than-50% rule, not the single most likely outcome or an expected-value average.
Why not A: This confuses recognizing some benefit with recognizing the full claimed benefit. Passing recognition does not permit immediate recognition of the entire claimed benefit; the amount is limited by ASC 740's measurement model.
Why not B: Tempting because many estimates use a most-likely approach, and the stem notes recognition was met; however ASC 740 does not measure uncertain tax positions by choosing the single most likely outcome once recognized. It uses the cumulative >50% settlement rule.
Why not C: Expected value is a familiar measurement in other GAAP contexts, but ASC 740 prescribes a specific settlement-probability model for uncertain tax positions rather than a probability-weighted average.
Question 5
Hint
Handle each position separately: first assess recognition based only on technical merits; then, for any recognized position, use the ASC 740 measurement rule to find the largest amount whose cumulative probability exceeds 50%.
Answer B. ASC 740 uses a two-step model: first determine whether a tax position is more likely than not to be sustained on technical merits; then measure any recognized position as the largest amount with cumulative probability greater than 50%. Position 1 meets the recognition threshold; cumulative probability for $120,000 is 35% (<50%), while cumulative probability for $90,000 is 35% + 25% = 60% (>50%), so Position 1 is measured at $90,000. Position 2 fails the more-likely-than-not recognition threshold, so no benefit is recognized for it.
Why not A: Tempting because it sums both claimed benefits ($120,000 + $40,000). It's incorrect because Position 2 does not meet ASC 740's recognition threshold and Position 1 must be measured using the cumulative-probability (>50%) rule rather than recording the full claimed amount.
Why not C: Tempting because it adds the correctly measured $90,000 for Position 1 to Position 2's $40,000. It's wrong because Position 2 fails the more-likely-than-not recognition test and therefore cannot be recognized.
Why not D: Tempting because $120,000 is the largest single claimed benefit for Position 1. It's incorrect because $120,000 alone has only a 35% probability (<50%); ASC 740 requires selecting the largest amount with cumulative probability >50%, which yields $90,000 here.
Question 6
Hint
Compute the gross deferred tax asset first, then ask whether any portion must be reduced because it is not more likely than not to be realized.
Answer A. The gross deferred tax asset is $60,000 ($240,000 × 25%). Under ASC 740, a deferred tax asset is reduced by a valuation allowance for the portion that is not more likely than not to be realized. Because Pine concludes that $45,000 of the tax benefit will be realized, it reports a net deferred tax asset of $45,000 and a valuation allowance of $15,000.
Why not B: This is the amount of the valuation allowance (gross DTA of $60,000 less the $45,000 expected realizable benefit). The question asks for the net deferred tax asset reported, not the valuation allowance.
Why not C: Tempting if a candidate overreads the realizability limit and assumes any uncertainty means no deferred tax asset can be recognized. That is incorrect here because Pine expects to realize part of the tax benefit; ASC 740 allows recognition of the realizable portion with a valuation allowance for the remainder.
Why not D: This answer shows the gross deferred tax asset computed from the temporary difference but ignores the valuation allowance required for the portion not more likely than not to be realized. Pine cannot report the full $60,000 when only $45,000 is expected to be realizable.
Common questions
What is the difference between a valuation allowance and an uncertain tax position?
A valuation allowance reduces a deferred tax asset that may not be realized. An uncertain tax position requires technical support for recognition and a separate measurement of the supported benefit.
Do cumulative losses require a full valuation allowance under ASC 740?
No. Reversing taxable temporary differences can support realization despite losses if they provide taxable income where and when the deductions can be used.
How do you measure an uncertain tax position under ASC 740?
First pass recognition on technical merits, assuming examination with full knowledge. Then rank benefits from largest to smallest and select the largest amount whose cumulative probability exceeds 50%.
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