First Data 2014 Annual Report Download - page 149

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
(A Joint Venture)
Financial Statements
December 31, 2014 and 2013
(Dollars in thousands, unless otherwise noted)
 
No provision is made in the accounts of the Company for federal or state income taxes because all items of income expense and other items affecting
taxable income are allocated to the Members for inclusion in their income tax returns.
In accounting for income taxes, the Company follows the guidance in FASB ASC 740 (formerly FASB Interpretation No. 48), as amended by ASU
2009-06, Accounting for Uncertainty in Income Taxes. ASC 740 requires the Company to determine whether a tax position of the Company is more
likely than not to be sustained upon examination by the applicable taxing authority, including resolution of any related appeals or ligation
processes, based on the technical merits of the position. The tax benefit to be recognized is measured as the largest amount of benefit that is greater
than fifty percent likely of being realized upon ultimate settlement which could result in the Company recording a tax liability that would reduce
net assets. ASC 740 also provides guidance on thresholds, measurement, de-recognition, classification, interest and penalties, accounting in interim
periods, disclosure, and transition that is intended to provide better financial statement comparability among different entities. As an LLC and pass-
through entity, the Company does not incur tax expense and is not required to record a tax provision related to uncertain tax positions, in
accordance with the recognition, measurement, classification, and disclosure requirements of ASC 740-10. The U.S. is the major tax jurisdiction for
the Company. The tax returns of the Company can be examined by the relevant taxing authorities until the applicable statute of limitations has
expired, which is generally three to four years from the date the return is initially filed, depending on the specific jurisdiction. Based on analysis by
the Company, there were no material positions identified which did not meet the “more likely than not” standard as of and for the years ended
December 31, 2014 and 2013.
 
An equity account is maintained for each Member. In certain instances, the Members may be required to make additional contributions to the
Company. Such contributions will be determined on a pro-rata basis in accordance with each Members Membership Interest at the time of the
request and will be added to the Member’s equity account. Membership Interest is defined as the ownership percentage of the Company by each
member.
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