Summarize an uncertain tax position as a risk story with likelihood, impact, evidence, control status, and action.
Do not start the provision debate with the reserve number. Start with the risk story. Likelihood Name what would make the taxing authority challenge the position and what facts make the company more or less likely to prevail. Impact Show the exposure range, affected periods, penalty or interest sensitivity, and financial statement relevance. Response State what controls or evidence already reduce the risk and what action would reduce it before the next close. That makes the position manageable rather than mysterious.
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