Change to US GAAP may be costly for investors

The recent application of the new Interpretation No 48 (FIN 48) to US GAAP related to Accounting for uncertain tax positions may push some managers to revise their fund's NAV.
In fact, FIN 48 clarifies the accounting for uncertainty in income taxes recognized which may trigger adjustments to provisions made for tax uncertainties in the financial statements.
According to our information, hedge funds which made profit by investing in the Spanish equity market, in the last four years, may have to take a provision under FIN 48 to account for capital gains tax. The Spanish government reduced the tax for foreign entities to 18% in 2006 to bring it in line with local investor taxation. Other jurisdictions may be concerned (for example, Ireland has since 2009 a 25% capital gains tax).
It looks like funds reporting under IFRS standards are not concerned by those adjustments.
For a complete review of the differences in accounting for uncertain tax positions under IFRS and US GAAP, I recommend the following article:
http://www.internationaltaxreview.com/includes/magazine/PRINT.asp?SID=689631&ISS=23993&PUBID=35