UPS 2007 Annual Report Download - page 103

UNITED PARCEL SERVICE, INC. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—(Continued)
The following table summarizes the activity related to our unrecognized tax benefits (in millions):
Balance at January 1, 2007 .............................................. $373
Additions for tax positions of the current year ............................... 13
Additions for tax positions of prior years ................................... 34
Reductions for tax positions of prior years for:
Changes in judgment or facts ........................................ (12)
Settlements during the period ........................................ (49)
Lapses of applicable statute of limitations .............................. (4)
Balance at December 31, 2007 ........................................... $355
As of December 31, 2007, the total amount of gross unrecognized tax benefits that, if recognized, would
affect the effective tax rate was $134 million. We also had gross recognized tax benefits of $567 million recorded
as of December 31, 2007 associated with outstanding refund claims for prior tax years. Therefore, we had a net
receivable recorded with respect to prior year income tax matters in the accompanying balance sheets.
Our continuing practice is to recognize interest and penalties associated with income tax matters as a
component of income tax expense. Related to the uncertain tax benefits noted above, we accrued penalties of $5
million and interest of $36 million during 2007. As of December 31, 2007, we have recognized a liability for
penalties of $6 million and interest of $75 million. Additionally, we have recognized a receivable for interest of
$116 million for the recognized tax benefits associated with outstanding refund claims.
We file income tax returns in the U.S. federal jurisdiction, most U.S. state and local jurisdictions, and many
non-U.S. jurisdictions. As of December 31, 2007, we had substantially resolved all U.S. federal income tax
matters for tax years prior to 1999. In the third quarter of 2007, we entered into a Joint Stipulation to Dismiss the
case with the Department of Justice, effectively withdrawing our refund claim related to the 1994 disposition of a
subsidiary in France. The write-off of previously recognized tax receivable balances associated with the 1994
French matter resulted in a $37 million increase in income tax expense for the quarter. However, this increase
was offset by the impact of favorable developments with various other U.S. federal, U.S. state, and non-U.S.
contingency matters. In February 2008, the IRS completed its audit of the tax years 1999 through 2002 with only
a limited number of issues that will be considered by the IRS Appeals Office by 2009. The IRS is in the final
stages of completing its audit of the tax years 2003 through 2004. We anticipate that the IRS will conclude its
audit of the 2003 and 2004 tax years by 2009. With few exceptions, we are no longer subject to U.S. state and
local and non-U.S. income tax examinations by tax authorities for tax years prior to 1999, but certain U.S. state
and local matters are subject to ongoing litigation.
A number of years may elapse before an uncertain tax position is audited and ultimately settled. It is
difficult to predict the ultimate outcome or the timing of resolution for uncertain tax positions. It is reasonably
possible that the amount of unrecognized tax benefits could significantly increase or decrease within the next
twelve months. Items that may cause changes to unrecognized tax benefits include the timing of interest
deductions, the deductibility of acquisition costs, the consideration of filing requirements in various states, the
allocation of income and expense between tax jurisdictions and the effects of terminating an election to have a
foreign subsidiary join in filing a consolidated return. These changes could result from the settlement of ongoing
litigation, the completion of ongoing examinations, the expiration of the statute of limitations, or other
unforeseen circumstances. At this time, an estimate of the range of the reasonably possible change cannot be
made.
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