The hot new issue for the tax market is “FIN 48.” FIN 48 (FASB Interpretation No. 48) sets out guidelines on how tax positions that are subject to challenge should be recognized for financial accounting purposes and in entity’s financial statements. Also known as “Accounting for Uncertainty in Income Taxes—an interpretation of FASB Statement No. 109,” FIN 48 dramatically increases the compliance burden on U.S. enterprises and, as such, has been hailed as the most significant change in compliance since Sarbanes-Oxley. The stakes are high, and any customer who represents public companies, private companies, pass-thrus, not for profits, RICs or REITs that issue financial statements in accordance with GAAP must comply with FIN 48.