Investor Presentaiton
Description of the Matter
How We Addressed the Matter in
Our Audit
Unrecognized Income Tax Benefits
As discussed in Note 11 to the consolidated financial statements, the Company had
gross unrecognized income tax benefits of $1,235 million related to its uncertain tax
positions at December 31, 2022. Unrecognized income tax benefits are recorded under
the two-step recognition and measurement principles when a tax position does not meet
the more likely than not standard, or if a tax position meets the more likely than not
standard, but the financial statement tax benefit is reduced as part of the measurement
step.
The balance of unrecognized income tax benefits is comprised of uncertain tax positions
which meet the more likely than not standard, but the financial statement tax benefit has
been reduced as part of measuring the tax position.
Auditing management's analysis of its uncertain tax positions and resulting
unrecognized income tax benefits is complex as each tax position carries unique facts
and circumstances that must be evaluated and ultimate resolution is dependent on
uncontrollable factors such as the timing of finalizing resolutions of audit disputes
through reaching settlement agreements or concluding litigation, or changes in law, and
other factors.
We obtained an understanding, evaluated the design and tested the operating
effectiveness of management's controls related to uncertain tax positions. For example,
we tested controls over management's application of the two-step recognition and
measurement principles and management's review of the inputs and resultant
calculations of unrecognized income tax benefits, as well as the identification of
uncertain tax positions.
We also evaluated the Company's assessment of its uncertain tax positions. Our audit
procedures included, among others, evaluating management's accounting policies and
documentation to assess the appropriateness and consistency of the methods and
assumptions used to develop its uncertain tax positions and related unrecognized income
tax benefit amounts by jurisdiction. We also tested the completeness and accuracy of the
underlying data used by the Company. For example, we compared the unrecognized
income tax benefits recorded with similar positions in prior periods and assessed
management's consideration of current tax controversy and litigation, including current
year developments with respect to the Company's ongoing litigation and examinations
with respect to certain open tax years in the United States. We also assessed the
historical accuracy of management's estimates of its unrecognized income tax benefits
with the resolution of those positions. In addition, we involved tax subject matter
professionals to evaluate the application of relevant tax laws, regulations, case law, and
Company-specific controversy developments in the Company's recognition
determination. We have also evaluated the Company's income tax disclosures in
relation to these matters.
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