tax-provision-advisor
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How to install tax-provision-advisor?
raishin/vanguard-frontier-agentic/tax-provision-advisor
$npx -y skills add Raishin/vanguard-frontier-agentic --skill tax-provision-advisorMulti-jurisdiction corporate income tax provision reference framework covering ASC 740 (US GAAP) and IAS 12 (IFRS). Covers current vs. deferred tax, temporary and permanent differences, deferred tax asset/liability recognition and measurement, valuation allowance (more-likely-tha
SKILL.md
| 1 | # Tax Provision Advisor — Reference Skill |
| 2 | |
| 3 | ## Purpose |
| 4 | |
| 5 | Provide the complete multi-jurisdiction framework for corporate income tax provision advisory — from the recognition and measurement of current and deferred taxes through valuation allowances, uncertain tax positions, Pillar Two interactions, and ETR reconciliation. |
| 6 | |
| 7 | --- |
| 8 | |
| 9 | ## Part 1: ASC 740 vs. IAS 12 — Core Framework Comparison |
| 10 | |
| 11 | ### Scope and Recognition |
| 12 | |
| 13 | | Area | US GAAP (ASC 740) | IFRS (IAS 12) | |
| 14 | |---|---|---| |
| 15 | | Standard scope | All income taxes imposed by domestic or foreign jurisdictions | All income taxes (domestic and foreign), including withholding taxes on distributions to the reporting entity | |
| 16 | | Asset recognition threshold | All deferred tax assets recognized; reduce by **valuation allowance** if more likely than not (>50%) that some or all will not be realized (ASC 740-10-30-5) | Recognize deferred tax asset only to the extent it is **probable** (generally interpreted as >50%; aligned in practice) that sufficient future taxable profit will be available (IAS 12.24) | |
| 17 | | Deferred tax liability recognition | Recognize for all taxable temporary differences except the initial recognition exception (IAS 12 equivalent) and inside basis difference in investments under APB 23 / ASC 740-30 | Recognize for all taxable temporary differences except: (a) initial recognition of goodwill; (b) initial recognition exception (assets/liabilities where neither taxable profit nor accounting profit affected) | |
| 18 | | Rate used | **Enacted** rate at balance sheet date (ASC 740-10-25-47) — rate signed into law | **Substantively enacted** rate (IAS 12.47) — rate virtually certain to be enacted (e.g., passed by parliament awaiting royal assent) | |
| 19 | | Measurement | Tax basis × enacted rate; no discounting permitted | Tax basis × substantively enacted rate; no discounting permitted | |
| 20 | |
| 21 | **Key divergence — Rate**: Under US GAAP, a tax rate change affects deferred taxes only when the legislation is *signed into law*. Under IFRS, the rate change affects deferred taxes once *substantively enacted* — which can be earlier (e.g., a budget announcement in the UK Parliament). This frequently results in timing differences in the provision between GAAP and IFRS preparers facing the same legislative cycle. |
| 22 | |
| 23 | ### Temporary vs. Permanent Differences |
| 24 | |
| 25 | **Temporary difference** — difference between the tax basis of an asset or liability and its carrying amount that will reverse in future periods, giving rise to future taxable or deductible amounts. |
| 26 | |
| 27 | **Permanent difference** — difference between book income and taxable income that will never reverse (e.g., non-deductible penalties, tax-exempt municipal bond interest). |
| 28 | |
| 29 | | Difference Type | Deferred Tax Created? | US GAAP Citation | IFRS Citation | |
| 30 | |---|---|---|---| |
| 31 | | Taxable temporary difference (will increase taxable income when it reverses) | **Yes — deferred tax liability** | ASC 740-10-25-20 | IAS 12.15 | |
| 32 | | Deductible temporary difference (will decrease taxable income when it reverses) | **Yes — deferred tax asset** (subject to VA under ASC 740 / probable threshold under IAS 12) | ASC 740-10-25-5 | IAS 12.24 | |
| 33 | | Permanent difference | **No** | ASC 740-10-20 (definition) | IAS 12.22 (temporary difference definition excludes permanents) | |
| 34 | |
| 35 | Common temporary differences: |
| 36 | |
| 37 | | Item | Tax Treatment | Book Treatment | Creates | |
| 38 | |---|---|---|---| |
| 39 | | Accelerated depreciation / MACRS | Larger deduction in early years | Straight-line | **Taxable temp diff → DTL** | |
| 40 | | Net operating loss (NOL) carryforward | Future deduction | No book impact | **Deductible temp diff → DTA** | |
| 41 | | Warranty reserves | Deductible only when paid | Accrued when incurred | **Deductible temp diff → DTA** | |
| 42 | | Deferred revenue | Taxed when received | Recognized over time | **Deductible temp diff → DTA** | |
| 43 | | Goodwill amortization (US tax — §197) | 15-year straight-line deduction | Not amortized (GAAP) / amortized (IFRS 3 private) | **Taxable temp diff → DTL** | |
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