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The basics
November 2012
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Table of contents
Introduction..................................................................... 2
Financial statement presentation ..................................... 3
Interim financial reporting................................................ 6
Consolidation, joint venture accounting and equity
method investees/associates ........................................... 7
Business combinations ................................................... 12
Inventory ....................................................................... 14
Long-lived assets ........................................................... 15
Intangible assets............................................................ 17
Impairment of long-lived assets, goodwill and intangible
assets ........................................................................... 19
Financial instruments..................................................... 22
Foreign currency matters .............................................. 28
Leases ........................................................................... 30
Income taxes ................................................................. 33
Provisions and contingencies ......................................... 35
Revenue recognition ...................................................... 37
Share-based payments................................................... 39
Employee benefits other than share-based payments ..... 41
Earnings per share ......................................................... 43
Segment reporting ......................................................... 44
Subsequent events ........................................................ 45
Related parties .............................................................. 47
Appendix The evolution of IFRS ................................... 48
November 2012
Significant differences
US GAAP IFRS
Financial periods Generally, comparative financial Comparative information must be
required statements are presented; however, a disclosed with respect to the previous
single year may be presented in certain period for all amounts reported in the
circumstances. Public companies must current periods financial statements.
follow SEC rules, which typically require
balance sheets for the two most recent
years, while all other statements must
cover the three-year period ended on
the balance sheet date.
Layout of balance sheet No general requirement within IFRS does not prescribe a standard
and income statement US GAAP to prepare the balance sheet layout, but includes a list of minimum
and income statement in accordance line items. These minimum line items
with a specific layout; however, public are less prescriptive than the
companies must follow the detailed requirements in Regulation S-X.
requirements in Regulation S-X.
Balance sheet Debt for which there has been a Debt associated with a covenant
presentation of debt as covenant violation may be presented violation must be presented as current
current versus as non-current if a lender agreement to unless the lender agreement was
non-current waive the right to demand repayment reached prior to the balance sheet date.
for more than one year exists before
the financial statements are issued or
available to be issued.
US GAAP IFRS
Balance sheet Current or non-current classification, All amounts classified as non-current in
classification of deferred generally based on the nature of the the balance sheet.
tax assets and liabilities related asset or liability, is required.
Income statement No general requirement within US Entities may present expenses based on
classification of GAAP to classify income statement either function or nature (e.g., salaries,
expenses items by function or nature. However, depreciation). However, if function is
SEC registrants are generally required selected, certain disclosures about the
to present expenses based on function nature of expenses must be included in
(e.g., cost of sales, administrative). the notes.
Significant differences
US GAAP IFRS
Treatment of certain Each interim period is viewed as an Each interim period is viewed as a
costs in interim periods integral part of an annual period. As a discrete reporting period. A cost that
result, certain costs that benefit more does not meet the definition of an asset
than one interim period may be at the end of an interim period is not
allocated among those periods, deferred, and a liability recognized at
resulting in deferral or accrual of an interim reporting date must
certain costs. represent an existing obligation.
Income taxes are accounted for
based on an annual effective tax rate
(similar to US GAAP).
Convergence
The FASB planned to address presentation
and display of interim financial information
in US GAAP as part of the joint financial
statement presentation project. As noted in
the Financial statement presentation section,
further action is not expected on this project
in the near term.
Significant differences
US GAAP IFRS
Consolidation model Focus is on controlling financial Focus is on the power to control, with
interests. All entities are first control defined as the parents ability
evaluated as potential VIEs. If a VIE, to govern the financial and operating
the applicable guidance in ASC 810 is policies of an entity to obtain benefits.
followed (below). If an entity is not a Control is presumed to exist if the
VIE, it is evaluated for control by parent owns more than 50% of the
voting rights. Potential voting rights votes, and potential voting rights must
are generally not included in either be considered. Notion of de facto
evaluation. control also may be considered.
Special purpose entities The guidance in ASC 810 requires the Under SIC-12, SPEs (entities created to
(SPE) / VIEs primary beneficiary (determined based accomplish a narrow and well-defined
on the consideration of power and objective) are consolidated when the
benefits) to consolidate the VIE. For substance of the relationship indicates
certain specified VIEs, the primary that an entity controls the SPE.
beneficiary is determined
quantitatively based on a majority of
the exposure to variability.
US GAAP IFRS
Preparation of The reporting entity and the The financial statements of a parent and
consolidated financial consolidated entities are permitted its consolidated subsidiaries are
statements different to have different year-ends of up to prepared as of the same date. When the
reporting dates of parent three months. end of the reporting period differs for
and subsidiary(ies) The effects of significant events the parent and a subsidiary, the
occurring between the reporting dates subsidiary prepares (for consolidation
of the reporting entity and the purposes) additional financial
controlled entities are disclosed in the statements as of the same date as the
financial statements. financial statements of the parent
unless it is impracticable to do so.
However, when the difference between
the end of the reporting period of the
parent and subsidiary is three months or
less, the financial statements of the
subsidiary may be adjusted for the
effects of significant transactions and
events, rather than preparing additional
financial statements as of the parents
reporting date.
Changes in ownership Transactions that result in decreases Consistent with US GAAP, except that
interest in a subsidiary in ownership interest in a subsidiary this guidance applies to all subsidiaries
without loss of control without a loss of control are accounted under IAS 27(R), even those that are
for as equity transactions in the not businesses or nonprofit activities,
consolidated entity (that is, no gain or those that involve sales of in substance
loss is recognized) when: (1) subsidiary real estate or conveyance of oil and gas
is a business or nonprofit activity (with mineral rights. In addition, IAS 27(R)
two exceptions: a sale of in substance does not address whether that guidance
real estate and a conveyance of oil and should be applied to transactions
gas mineral rights); or (2) subsidiary is involving non-subsidiaries that are
not a business or nonprofit activity, businesses or nonprofit activities.
but the substance of the transaction is
not addressed directly by other
ASC Topics.
US GAAP IFRS
Loss of control of a For certain transactions that result in a Consistent with US GAAP, except that
subsidiary loss of control of a subsidiary or a this guidance applies to all subsidiaries
group of assets, any retained under IAS 27(R), even those that are
noncontrolling investment in the not businesses or nonprofit activities or
former subsidiary or group of assets is those that involve sales of in substance
re-measured to fair value on the date real estate or conveyance of oil and gas
control is lost, with the gain or loss mineral rights. In addition, IAS 27(R)
included in income along with any gain does not address whether that guidance
or loss on the ownership interest sold. should be applied to transactions
involving non-subsidiaries that are
This accounting is limited to the
businesses or nonprofit activities.
following transactions: (1) loss of
IAS 27(R) also does not address the
control of a subsidiary that is a
derecognition of assets outside the
business or nonprofit activity or a
loss of control of a subsidiary.
group of assets that is a business or
nonprofit activity (with two exceptions:
a sale of in substance real estate, or a
conveyance of oil and gas mineral
rights); (2) loss of control of a
subsidiary that is not a business or
nonprofit activity if the substance of
the transaction is not addressed
directly by other ASC Topics.
Equity method Potential voting rights are generally In determining significant influence,
investments not considered in the determination of potential voting rights are considered if
significant influence. currently exercisable.
ASC 825-10, Financial Instruments, The fair value option is not available to
gives entities the option to account for investors (other than venture capital
certain investments at fair value. If organizations, mutual funds, unit trusts,
management does not elect to use the and similar entities) to account for their
fair value option, the equity method of investments in associates.
accounting is required.
IAS 28 generally requires investors
(other than venture capital
organizations, mutual funds, unit trusts,
and similar entities) to use the equity
method of accounting for their
investments in associates in consolidated
financial statements. If separate financial
statements are presented (i.e., by a
parent or investor), subsidiaries and
associates can be accounted for at either
cost or fair value.
US GAAP IFRS
Joint ventures Generally accounted for using the IAS 31, Interests in Joint Ventures,
equity method of accounting (or at fair permits either the proportionate
value, if the fair value option is consolidation method or the equity
elected). Proportionate consolidation method of accounting for interests in
may be permitted in limited jointly controlled entities. The fair value
circumstances to account for interests option is not available to investors
in unincorporated entities in certain (other than venture capital
industries where it is an established organizations, mutual funds, unit trusts,
practice (i.e., in the construction and and similar entities) to account for their
extractive industries). investments in jointly controlled entities.
Significant differences
US GAAP IFRS
Measurement of Noncontrolling interest is measured at Noncontrolling interest components
noncontrolling interest fair value, including goodwill. that are present ownership interests
and entitle their holders to a
proportionate share of the acquirees
net asset in the event of liquidation may
be measured at: (1) fair value, including
goodwill, or (2) at the noncontrolling
interests proportionate share of the
fair value of the acquirees identifiable
net assets, exclusive of goodwill.
All other components of noncontrolling
interest are measured at fair value
unless another measurement basis is
required by IFRS.
The choice is available on a
transaction-by-transaction basis.
US GAAP IFRS
Assets and liabilities Initial recognition and measurement Initial recognition and measurement
arising from Assets and liabilities arising from Liabilities arising from contingencies
contingencies contingencies are recognized at fair are recognized as of the acquisition
value (in accordance with ASC 820, date if there is a present obligation that
Fair Value Measurement) if the fair arises from past events and the fair
value can be determined during the value can be measured reliably.
measurement period. Otherwise, those Contingent assets are not recognized.
assets or liabilities are recognized at
the acquisition date in accordance with
ASC 450, Contingencies, if those
criteria for recognition are met.
Contingent assets and liabilities that
do not meet either of these recognition
criteria at the acquisition date are
subsequently accounted for in
accordance with other applicable
literature, including ASC 450.
(See Provisions and Contingencies
for differences between ASC 450
and IAS 37).
Subsequent measurement Subsequent measurement
If contingent assets and liabilities are Liabilities subject to contingencies are
initially recognized at fair value, an subsequently measured at the higher
acquirer should develop a systematic of: (1) the amount that would be
and rational basis for subsequently recognized in accordance with IAS 37,
measuring and accounting for those or (2) the amount initially recognized
assets and liabilities depending on less, if appropriate, cumulative
their nature. amortization recognized in accordance
If amounts are initially recognized and with IAS 18.
measured in accordance with ASC 450,
the subsequent accounting and
measurement should be based on
that guidance.
Combination of entities The receiving entity records the net Outside the scope of IFRS 3(R). In
under common control assets at their carrying amounts in practice, either follow an approach
the accounts of the transferor similar to US GAAP (historical cost) or
(historical cost). apply the acquisition method (fair
value) if there is substance to the
transaction (policy election).
Other differences may arise due to different contingent consideration, initial recognition and
accounting requirements of other existing measurement of income taxes, initial recognition
US GAAP and IFRS literature (e.g., identifying and measurement of employee benefits).
the acquirer, definition of control, replacement
of share-based payment awards, initial Convergence
classification and subsequent measurement of No further convergence is planned at this time.
Significant differences
US GAAP IFRS
Costing methods LIFO is an acceptable method. LIFO is prohibited. Same cost formula
Consistent cost formula for all must be applied to all inventories
inventories similar in nature is not similar in nature or use to the entity.
explicitly required.
Measurement Inventory is carried at the lower of cost Inventory is carried at the lower of cost
or market. Market is defined as current or net realizable value. Net realizable
replacement cost, but not greater than value is defined as the estimated selling
net realizable value (estimated selling price less the estimated costs of
price less reasonable costs of completion and the estimated costs
completion and sale) and not less than necessary to make the sale.
net realizable value reduced by a
normal sales margin.
Permanent inventory Permanent markdowns do not affect Permanent markdowns affect the
markdowns under the the gross margins used in applying the average gross margin used in applying
retail inventory method RIM. Rather, such markdowns reduce the RIM. Reduction of the carrying cost
(RIM) the carrying cost of inventory to net of inventory to below the lower of cost
realizable value, less an allowance for or net realizable value is not allowed.
an approximately normal profit margin,
which may be less than both original
cost and net realizable value.
Convergence
No further convergence is planned at this time.
Similarities Depreciation
Although US GAAP does not have a Depreciation of long-lived assets is required
comprehensive standard that addresses on a systematic basis under both accounting
long-lived assets, its definition of property, plant models. ASC 250, Accounting Changes and
and equipment is similar to IAS 16, Property, Error Corrections, and IAS 8, Accounting
Plant and Equipment, which addresses tangible Policies, Changes in Accounting Estimates and
assets held for use that are expected to be used Errors, both treat changes in residual value and
for more than one reporting period. Other useful economic life as a change in accounting
concepts that are similar include the following: estimate requiring prospective treatment.
Significant differences
US GAAP IFRS
Measurement of Eligible borrowing costs do not include Eligible borrowing costs include
borrowing costs exchange rate differences. Interest exchange rate differences from foreign
earned on the investment of borrowed currency borrowings. For borrowings
funds generally cannot offset interest associated with a specific qualifying
costs incurred during the period. asset, actual borrowing costs are
For borrowings associated with a capitalized offset by investment
income earned on those borrowings.
specific qualifying asset, borrowing
costs equal to the weighted-average
accumulated expenditures times the
borrowing rate are capitalized.
Costs of a major Multiple accounting models have Costs that represent a replacement of
overhaul evolved in practice, including: expense a previously identified component of an
costs as incurred, capitalize costs and asset are capitalized if future economic
amortize through the date of the next benefits are probable and the costs can
overhaul, or follow the IFRS approach. be reliably measured.
Significant differences
US GAAP IFRS
Development costs Development costs are expensed as Development costs are capitalized
incurred unless addressed by guidance when technical and economic feasibility
in another ASC Topic. Development of a project can be demonstrated in
costs related to computer software accordance with specific criteria,
developed for external use are including: demonstrating technical
capitalized once technological feasibility feasibility, intent to complete the asset,
is established in accordance with and ability to sell the asset in the
specific criteria (ASC 985-20). In the future. Although application of these
case of software developed for internal principles may be largely consistent
use, only those costs incurred during with ASC 985-20 and ASC 350-40,
the application development stage (as there is no separate guidance
defined in ASC 350-40, Intangibles addressing computer software
Goodwill and Other Internal-Use development costs.
Software) may be capitalized.
Advertising costs Advertising and promotional costs are Advertising and promotional costs are
either expensed as incurred or expensed as incurred. A prepayment
expensed when the advertising takes may be recognized as an asset only
place for the first time (policy choice). when payment for the goods or
Direct response advertising may be services is made in advance of the
capitalized if the specific criteria in entity having access to the goods or
ASC 340-20, Other Assets and receiving the services.
Deferred Costs Capitalized
Advertising Costs, are met.
US GAAP IFRS
Convergence
No further convergence is planned at this time.
intangible assets
Similarities ASC 350, Intangibles Goodwill and Other,
Under both US GAAP and IFRS, long-lived Impairment or Disposal of Long-Lived Assets
assets are not tested annually, but rather when subsections of ASC 360-10, Property, Plant
there are similarly defined indicators of and Equipment, and IAS 36, Impairment of
impairment. Both standards require goodwill Assets, apply to most long-lived and intangible
and intangible assets with indefinite useful lives assets, although some of the scope exceptions
to be tested at least annually for impairment listed in the standards differ. Despite the
and more frequently if impairment indicators similarity in overall objectives, differences exist
are present. In addition, both US GAAP and in the way impairment is tested, recognized
IFRS require that the impaired asset be written and measured.
down and an impairment loss recognized.
Significant differences
US GAAP IFRS
Method of determining Two-step approach requires that a One-step approach requires that
impairment long-lived recoverability test be performed first impairment loss calculation be
assets (carrying amount of the asset is performed if impairment indicators
compared with the sum of future exist.
undiscounted cash flows generated
through use and eventual disposition).
If it is determined that the asset is not
recoverable, an impairment loss
calculation is required.
Impairment loss The amount by which the carrying The amount by which the carrying
calculation long-lived amount of the asset exceeds its fair amount of the asset exceeds its
assets value, as calculated in accordance with recoverable amount; recoverable
ASC 820. amount is the higher of: (1) fair value
less costs to sell and (2) value in use
(the present value of future cash flows
in use, including disposal value).
US GAAP IFRS
Method of determining Companies have the option to One-step approach requires that an
impairment goodwill qualitatively assess whether it is more impairment test be done at the CGU
likely than not that the fair value of a level by comparing the CGUs carrying
reporting unit is less than its carrying amount, including goodwill, with its
amount. If so, a two-step approach recoverable amount.
requires a recoverability test to be
performed first at the reporting unit level
(carrying amount of the reporting unit is
compared with the reporting unit fair
value). If the carrying amount of the
reporting unit exceeds its fair value, then
impairment testing must be performed.
Impairment loss The amount by which the carrying Impairment loss on the CGU (amount
calculation goodwill amount of goodwill exceeds the implied by which the CGUs carrying amount,
fair value of the goodwill within its including goodwill, exceeds its
reporting unit. recoverable amount) is allocated first
to reduce goodwill to zero, then,
subject to certain limitations, the
carrying amount of other assets in the
CGU are reduced pro rata, based on the
carrying amount of each asset.
Impairment loss The amount by which the carrying value The amount by which the carrying
calculation of the asset exceeds its fair value. value of the asset exceeds its
indefinite-lived recoverable amount.
intangible assets
Reversal of loss Prohibited for all assets to be held Prohibited for goodwill. Other
and used. long-lived assets must be reviewed at
the end of each reporting period for
reversal indicators. If appropriate, loss
should be reversed up to the newly
estimated recoverable amount, not to
exceed the initial carrying amount
adjusted for depreciation.
Convergence
No further convergence is planned at this time.
In July 2012, the FASB issued guidance that
gives companies the option to perform a
qualitative impairment assessment for
indefinite-lived intangible assets that may allow
them to skip the annual fair value calculation.
The guidance is effective for annual and interim
impairment tests performed for fiscal years
beginning after 15 September 2012. Early
adoption is permitted. The guidance is similar
to the qualitative screen to test goodwill
for impairment.
Significant differences
US GAAP IFRS
US GAAP IFRS
Impairment recognition Declines in fair value below cost may Generally, only objective evidence of
available-for-sale (AFS) result in an impairment loss being one or more credit loss events result
debt instruments recognized in the income statement on in an impairment being recognized in
an AFS debt instrument due solely to a the statement of comprehensive
change in interest rates (risk-free or income for an AFS debt instrument.
otherwise) if the entity has the intent The impairment loss is measured as
to sell the debt instrument or it is more the difference between the debt
likely than not that it will be required instruments amortized cost basis and
to sell the debt instrument before its fair value.
its anticipated recovery. In this
circumstance, the impairment loss is
measured as the difference between
the debt instruments amortized cost
basis and its fair value.
When a credit loss exists, but (1) the
entity does not intend to sell the debt
instrument, or (2) it is not more likely
than not that the entity will be required
to sell the debt instrument before the
recovery of the remaining cost basis,
the impairment is separated into the
amount representing the credit loss
and the amount related to all other
factors. The amount of the total
impairment related to the credit loss is
recognized in the income statement
and the amount related to all other
factors is recognized in other
comprehensive income, net of
applicable taxes.
US GAAP IFRS
Impairment recognition The impairment loss of an HTM The impairment loss of an HTM
held-to-maturity (HTM) instrument is measured as the instrument is measured as the
debt instruments difference between its fair value and difference between the carrying
amortized cost basis. The amount of amount of the instrument and the
the total impairment related to the present value of estimated future cash
credit loss is recognized in the income flows discounted at the instruments
statement, and the amount related to original effective interest rate. The
all other factors is recognized in other carrying amount of the instrument is
comprehensive income. reduced either directly or through the
The carrying amount of an HTM use of an allowance account. The
investment after recognition of an amount of impairment loss is
impairment is the fair value of the debt recognized in the statement of
instrument at the date of the comprehensive income.
impairment. The new cost basis of the
debt instrument is equal to the
previous cost basis less the impairment
recognized in the income statement.
The impairment recognized in other
comprehensive income is accreted to
the carrying amount of the HTM
instrument through other
comprehensive income over its
remaining life.
Definition of a derivative To meet the definition of a derivative, The IFRS definition of a derivative does
and scope exceptions an instrument must have one or more not include a requirement that a
underlyings, one or more notional notional amount be indicated, nor is
amounts or payment provisions or net settlement a requirement. Certain
both, must require no initial net of the scope exceptions under IFRS
investment, as defined, and must be differ from those under US GAAP.
able to be settled net, as defined.
Certain scope exceptions exist for
instruments that would otherwise meet
these criteria.
US GAAP IFRS
Hedging a risk The risk components that may be Allows risks associated with only a
component of a financial hedged are specifically defined by the portion of the instruments cash flows
instrument literature, with no additional flexibility. or fair value (such as one or more
selected contractual cash flows or
portions of them or a percentage of the
fair value) provided that effectiveness
can be measured: that is, the portion is
identifiable and separately measurable.
Hedge effectiveness The shortcut method for interest rate The shortcut method for interest rate
swaps hedging recognized debt swaps hedging recognized debt is not
instruments is permitted. permitted.
The long-haul method of assessing and Under IFRS, assessment and
measuring hedge effectiveness for a fair measurement of hedge effectiveness
value hedge of the benchmark interest considers only the change in fair value
rate component of a fixed rate debt of the designated hedged portion of the
instrument requires that all contractual instruments cash flows, as long as the
cash flows be considered in calculating portion is identifiable and separately
the change in the hedged items fair measurable.
value even though only a component of
the contractual coupon payment is the
designated hedged item.
Hedge effectiveness Permitted. Not permitted.
inclusion of options
time value
Derecognition
Derecognition of Derecognition of financial assets Derecognition of financial assets is
financial assets (i.e., sales treatment) occurs when based on a mixed model that considers
effective control over the financial transfer of risks and rewards and
asset has been surrendered: control. Transfer of control is
The transferred financial assets are considered only when the transfer of
legally isolated from the transferor risks and rewards assessment is not
conclusive. If the transferor has neither
Each transferee (or, if the retained nor transferred substantially
transferee is a securitization entity all of the risks and rewards, there is
or an entity whose sole purpose is to then an evaluation of the transfer of
facilitate an asset-backed financing, control. Control is considered to be
each holder of its beneficial surrendered if the transferee has the
interests), has the right to pledge or practical ability to unilaterally sell the
exchange the transferred financial transferred asset to a third party
assets (or beneficial interests) without restrictions. There is no legal
The transferor does not maintain isolation test.
effective control over the
transferred financial assets or
beneficial interests (e.g., through a
call option or repurchase
agreement)
US GAAP IFRS
The derecognition criteria may be The derecognition provisions may be
applied to a portion of a financial asset applied to a portion of a financial asset
only if it mirrors the characteristics of if the cash flows are specifically
the original entire financial asset. identified or represent a pro rata share
of the financial asset or a pro rata
share of specifically identified cash
flows.
Loans and receivables
Measurement effective Requires catch-up approach, Requires the original effective interest
interest method retrospective method or prospective rate to be used throughout the life of the
method of calculating the interest for instrument for all financial assets and
amortized cost-based assets, liabilities, except for certain reclassified
depending on the type of instrument. financial assets, in which case the effect
of increases in cash flows are recognized
as prospective adjustments to the
effective interest rate.
Measurement loans Unless the fair value option is elected, Loans and receivables are carried at
and receivables loans and receivables are classified as amortized cost unless classified into
either: (1) held for investment, which the fair value through profit or loss
are measured at amortized cost, or category or the available for sale
(2) held for sale, which are measured category, both of which are carried at
at the lower of cost or fair value. fair value on the balance sheet.
Fair value after the adoption of IFRS 13
Day one gains and losses Entities are not precluded from Day one gains and losses on financial
recognizing day one gains and losses on instruments are recognized only when
financial instruments reported at fair their fair value is evidenced by a
value even when all inputs to the quoted price in an active market for an
measurement model are not identical asset or liability (i.e., a level 1
observable. Unlike IFRS, US GAAP or level 2 input) or based on a valuation
contains no specific requirements technique that uses only data from
regarding the observability of inputs, observable markets.
thereby potentially allowing for the
recognition of gains or losses at initial
recognition of an asset or liability even
when the fair value measurement is
based on a valuation model with
significant unobservable inputs
(i.e., Level 3 measurements).
Practical expedient for Entities are provided a practical No practical expedient to assume that
alternative investments expedient to estimate the fair value of NAV represents the fair value of
certain alternative investments (e.g., a certain alternative investments.
limited partner interest in a Private
Equity fund) using net asset value per
share (NAV) or its equivalent.
Significant differences
US GAAP IFRS
US GAAP IFRS
Convergence
No further convergence is planned at this time.
Significant differences
US GAAP IFRS
Lease of real estate A lease of land and buildings that The land and building elements of the
transfers ownership to the lessee or lease are considered separately when
contains a bargain purchase option evaluating all indicators unless the
would be classified as a capital lease by amount that would initially be
the lessee, regardless of the relative recognized for the land element is
value of the land. immaterial, in which case they would
If the fair value of the land at inception be treated as a single unit for purposes
represents less than 25% of the total of lease classification. There is no 25%
fair value of the lease, the lessee test to determine whether to consider
accounts for the land and building the land and building separately when
components as a single unit for evaluating certain indicators.
purposes of evaluating the 75% and
90% tests noted above.
Otherwise, the lessee must consider
the land and building components
separately for purposes of evaluating
other lease classification criteria.
(Note: Only the building is subject to
the 75% and 90% tests in this case.)
Recognition of a gain or If the seller does not relinquish more Gain or loss is recognized immediately,
loss on a sale and than a minor part of the use of the subject to adjustment if the sales price
leaseback when the asset, gain or loss is generally deferred differs from fair value.
leaseback is an and amortized over the lease term. If
operating leaseback the seller relinquishes more than a
minor part of the use of the asset, then
part or all of a gain may be recognized
depending on the amount relinquished.
(Note: Does not apply if real estate is
involved, as the specialized rules are
very restrictive with respect to the
sellers continuing involvement, and
they may not allow for recognition of
the sale).
Recognition of gain or Generally, same as above for operating Gain or loss deferred and amortized
loss on a sale-leaseback leaseback in which the seller does not over the lease term.
when the leaseback is a relinquish more than a minor part of
capital leaseback the use of the asset.
Other differences include: (1) the treatment of rate used to discount minimum lease payments
a leveraged lease by a lessor under ASC 840 to the present value for purposes of
(IAS 17 does not have such classification), determining lease classification and
(2) real estate sale-leasebacks, (3) real estate subsequent recognition of a capital lease,
sales-type leases, (4) leases of land and (5) the including in the event of a renewal.
Convergence
As part of their convergence efforts, the
Boards are jointly redeliberating their
exposure drafts on lease accounting that
would create a common standard for lease
accounting and require lessees to recognize
the assets and liabilities arising under most
lease contracts on their balance sheets.
The Boards plan to re-expose their proposals in
2013 due to the significant changes made
during redeliberations.
Significant differences
US GAAP IFRS
Tax basis Tax basis is a question of fact under the Tax basis is generally the amount
tax law. For most assets and liabilities, deductible or taxable for tax purposes.
there is no dispute on this amount; The manner in which management
however, when uncertainty exists, it is intends to settle or recover the
determined in accordance with carrying amount affects the
ASC 740-10-25. determination of tax basis.
Taxes on intercompany Requires taxes paid on intercompany Requires taxes paid on intercompany
transfers of assets that profits to be deferred and prohibits the profits to be recognized as incurred
remain within a recognition of deferred taxes on and requires the recognition of
consolidated group temporary differences between the tax deferred taxes on temporary
bases of assets transferred between differences between the tax bases of
entities/tax jurisdictions that remain assets transferred between entities/tax
within the consolidated group. jurisdictions that remain within the
consolidated group.
Uncertain tax positions ASC 740-10-25 requires a two-step IFRS does not include specific guidance.
process, separating recognition from IAS 12 indicates that tax assets and
measurement. A benefit is recognized liabilities should be measured at the
when it is more likely than not to be amount expected to be paid based on
sustained based on the technical merits enacted or substantively enacted tax
of the position. Detection risk is legislation. Some adopt a one-step
precluded from being considered in approach that recognizes all uncertain
the analysis. The amount of benefit to tax positions at an expected value.
be recognized is based on the largest Others adopt a two-step approach
amount of tax benefit that is greater that recognizes only those uncertain
than 50% likely of being realized upon tax positions that are considered more
ultimate settlement. likely than not to result in a cash
outflow. Practice varies regarding
the consideration of detection risk in
the analysis.
US GAAP IFRS
Initial recognition Does not include an exemption like that Deferred tax effects arising from the
exemption under IFRS for non-recognition of initial recognition of an asset or liability
deferred tax effects for certain assets are not recognized when: (1) the
or liabilities. amounts did not arise from a business
combination, and (2) upon occurrence,
the transaction affects neither
accounting nor taxable profit
(e.g., acquisition of non-deductible
assets).
Recognition of deferred Recognized in full (except for certain Amounts are recognized only to the
tax assets outside basis differences), but extent it is probable (similar to more
valuation allowance reduces asset to likely than not under US GAAP) that
the amount that is more likely than not they will be realized.
to be realized.
Calculation of deferred Enacted tax rates must be used. Enacted or substantively enacted tax
tax asset or liability rates as of the balance sheet date must
be used.
Recognition of deferred Recognition not required for Recognition required unless the
tax liabilities from investment in a foreign subsidiary or reporting entity has control over the
investments in corporate JV that is essentially timing of the reversal of the temporary
subsidiaries or joint permanent in duration, unless it difference and it is probable (more
ventures (JVs) (often becomes apparent that the difference likely than not) that the difference will
referred to as outside will reverse in the foreseeable future. not reverse in the foreseeable future.
basis differences)
Significant differences
US GAAP IFRS
Recognition threshold A loss must be probable (in which A loss must be probable (in which
probable is interpreted as likely) to be probable is interpreted as more likely
recognized. While ASC 450 does not than not) to be recognized. More likely
ascribe a percentage to probable, it is than not refers to a probability of
intended to denote a high likelihood greater than 50%.
(e.g., 70% or more).
Discounting provisions Provisions may be discounted only Provisions should be recorded at the
when the amount of the liability and estimated amount to settle or transfer
the timing of the payments are fixed the obligation taking into consideration
or reliably determinable, or when the the time value of money. The discount
obligation is a fair value obligation rate to be used should be a pre-tax
(e.g., an asset retirement obligation rate (or rates) that reflect(s) current
under ASC 410-20). The discount rate market assessments of the time value
to be used is dependent upon the nature of money and the risks specific to the
of the provision, and may vary from liability.
that used under IFRS. However, when a
provision is measured at fair value, the
time value of money and the risks
specific to the liability should be
considered.
US GAAP IFRS
Measurement of Most likely outcome within range Best estimate of obligation should be
provisions range of should be accrued. When no one accrued. For a large population of
possible outcomes outcome is more likely than the others, items being measured, such as
the minimum amount in the range of warranty costs, best estimate is
outcomes should be accrued. typically expected value, although
midpoint in the range may also be used
when any point in a continuous range is
as likely as another. Best estimate for a
single obligation may be the most likely
outcome, although other possible
outcomes should still be considered.
Restructuring costs Under ASC 420, once management has Once management has demonstrably
committed to a detailed exit plan, each committed (i.e., a legal or constructive
type of cost is examined to determine obligation has been incurred) to a
when recognized. Involuntary employee detailed exit plan, the general
termination costs under a one-time provisions of IAS 37 apply. Costs
benefit arrangement are recognized typically are recognized earlier than
over future service period, or under US GAAP because IAS 37
immediately if there is no future service focuses on the exit plan as a whole,
required. Other exit costs are expensed rather than individual cost components
when incurred. of the plan.
Convergence
The IASB proposed amendments to IAS 37 in
2005 and then proposed amendments to
IAS 37s measurement provisions in January
2010. The IASB is reviewing the project as part
of its agenda consultation process in 2012.
US GAAP IFRS
Sale of goods Public companies must follow SAB Revenue is recognized only when risks
Topic 13, Revenue Recognition, which and rewards of ownership have been
requires that delivery has occurred (the transferred, the buyer has control of
risks and rewards of ownership have the goods, revenues can be measured
been transferred), there is persuasive reliably and it is probable that the
evidence of an arrangement, the fee is economic benefits will flow to the
fixed or determinable and collectibility company.
is reasonably assured.
US GAAP IFRS
Multiple elements Specific criteria are required in order IAS 18 requires recognition of revenue
for each element to be a separate unit related to an element of a transaction if
of accounting, including delivered that element has commercial
elements must have standalone value. substance on its own; otherwise, the
If those criteria are met, revenue for separate elements must be linked and
each element of the transaction may be accounted for as a single transaction.
recognized when the element is IAS 18 does not provide specific
complete. criteria for making that determination.
Construction contracts Construction contracts are accounted Construction contracts are accounted
for using the percentage-of-completion for using the percentage-of-completion
method if certain criteria are met. method if certain criteria are met.
Otherwise, the completed contract Otherwise, revenue recognition is
method is used. limited to recoverable costs incurred.
The completed contract method is
not permitted.
Construction contracts may be, but Construction contracts are combined
are not required to be, combined or or segmented if certain criteria are
segmented if certain criteria are met. met. Criteria under IFRS differ from
those in US GAAP.
Significant differences
US GAAP IFRS
Transactions with The US GAAP definition of an employee IFRS has a more general definition of
non-employees focuses primarily on the common law an employee that includes individuals
definition of an employee. who provide services similar to those
rendered by employees.
Either the fair value of: (1) the goods or Fair value of the transaction should be
services received, or (2) the equity based on the fair value of the goods or
instruments granted is used to value services received, and only on the fair
the transaction, whichever is more value of the equity instruments granted
reliably measurable. in the rare circumstance that the fair
value of the goods and services cannot
be reliably estimated.
Measurement date is the earlier of: Measurement date is the date the
(1) the date at which a commitment entity obtains the goods or the
for performance by the counterparty counterparty renders the services.
is reached, or (2) the date at which the No performance commitment
counterpartys performance is complete. concept exists.
US GAAP IFRS
Measurement and Entities make an accounting policy Entities must recognize compensation
recognition of expense election to recognize compensation cost on an accelerated basis and each
awards with graded cost for awards containing only service individual tranche must be separately
vesting features conditions either on a straight-line measured.
basis or on an accelerated basis,
regardless of whether the fair value of
the award is measured based on the
award as a whole or for each individual
tranche.
Equity repurchase Liability classification is not required if Liability classification is required (no
features at employees employee bears risks and rewards of six-month consideration exists).
election equity ownership for at least six
months from the date the shares are
issued or vest.
Deferred taxes Calculated based on the cumulative Calculated based on the estimated tax
GAAP expense recognized and trued up deduction determined at each
or down upon realization of the reporting date (e.g., intrinsic value).
tax benefit. If the tax deduction exceeds cumulative
If the tax benefit exceeds the deferred compensation cost, deferred tax based
tax asset, the excess (windfall benefit) on the excess is credited to
is credited directly to shareholders shareholders equity. If the tax deduction
equity. Any shortfall of the tax benefit is less than or equal to cumulative
below the deferred tax asset is charged compensation cost, deferred taxes are
to shareholders equity to the extent of recorded in income.
prior windfall benefits, and to tax
expense thereafter.
Modification of vesting If an award is modified such that the Probability of achieving vesting terms
terms that are service or performance condition, before and after modification is not
improbable of which was previously improbable of considered. Compensation cost is the
achievement achievement, is probable of achievement grant date fair value of the award,
as a result of the modification, the together with any incremental fair
compensation cost is based on the fair value at the modification date.
value of the modified award at the
modification date. Grant date fair value
of the original award is not recognized.
Convergence
No further convergence is planned at this time.
share-based payments
(subsequent to the adoption of IAS 19 amendments, Employee Benefits)
Similarities accounting for defined benefit plans has many
ASC 715, Compensation Retirement Benefits, similarities as well. The defined benefit
and ASC 712, Compensation Nonretirement obligation is the present value of benefits that
Post-Employment Benefits, and IAS 19, have accrued to employees through services
Employee Benefits, as amended, are the rendered up to that date, based on actuarial
principal sources of guidance for employee methods of calculation. Both US GAAP and
benefits other than share-based payments IFRS require the funded status of the defined
under US GAAP and IFRS, respectively. Under benefit plan to be recognized on the balance
both US GAAP and IFRS, the net periodic sheet as the difference between the present
benefit cost recognized for defined value of the benefit obligation and the fair
contribution plans is based on the contribution value of plan assets, although IAS 19 limits the
due from the employer in each period. The net plan asset recognized for overfunded plans.
Significant differences
US GAAP IFRS
Actuarial method used Different methods are required Projected unit credit method is
for defined benefit plans depending on the characteristics of the required in all cases.
plans benefit formula.
Calculation of the Based on either the fair value of plan Limited to the net interest on the net
expected return on plan assets or a calculated value that defined benefit liability (asset)
assets smoothes the effect of short-term calculated using the benefit obligations
market fluctuations over five years. discount rate.
Settlements and Settlement gain or loss is recognized Gain or loss from settlement is
curtailments when the obligation is settled. recognized when it occurs. Change in
Curtailment losses are recognized when the defined benefit obligation from a
the curtailment is probable of occurring, curtailment is recognized at the earlier
while curtailment gains are recognized of when it occurs or when related
when the curtailment occurs. restructuring costs or termination
benefits are recognized.
US GAAP IFRS
Multi-employer pension Accounted for similar to a defined Plan is accounted for as either a defined
plans contribution plan. contribution or defined benefit plan
based on the terms (contractual and
constructive) of the plan. If a defined
benefit plan, must account for the
proportionate share of the plan similar
to any other defined benefit plan unless
sufficient information is not available.
Convergence
No further convergence is planned at this time.
Significant differences
US GAAP IFRS
Contracts that may be Such contracts are presumed to be Such contracts are always assumed to
settled in shares or cash settled in shares unless evidence is be settled in shares.
at the issuers option provided to the contrary (i.e., the
issuers intent or stated policy is to
settle in cash).
Treatment of Potentially issuable shares are included Potentially issuable shares are
contingently convertible in diluted EPS using the if-converted considered contingently issuable and
debt method if one or more contingencies are included in diluted EPS using the
relate to a market price trigger if-converted method only if the
(e.g., the entitys share price), even if contingencies are satisfied at the end
the market price trigger is not satisfied of the reporting period.
at the end of the reporting period.
Convergence
The Boards previously began a short-term
convergence project on earnings per share,
but now consider the project a lower priority and
do not expect further action in the near term.
Similarities
The requirements for segment reporting under
both ASC 280, Segment Reporting, and
IFRS 8, Operating Segments, apply to entities
with public reporting requirements and are
based on a management approach in
identifying the reportable segments. The two
standards are largely converged, and only
limited differences exist.
Significant differences
US GAAP IFRS
Determination of Entities with a matrix form of All entities determine segments based
segments organization (i.e., in some public on the management approach,
entities, the chief operating decision regardless of form of organization.
maker (CODM) is responsible for
different product and service lines
worldwide, while other CODMs are
responsible for specific geographic
areas) must determine segments based
on products and services
Disclosure requirements Entities are not required to disclose If regularly reported to the CODM,
segment liabilities even if reported to segment liabilities are a required
the CODM. disclosure.
Convergence
No further convergence is planned at this time.
Significant differences
US GAAP IFRS
Date through which Subsequent events are evaluated Subsequent events are evaluated
subsequent events must through the date the financial through the date that the financial
be evaluated statements are issued or available to be statements are authorized for issue.
issued. Financial statements are Depending on an entitys corporate
considered issued when they are widely governance structure and statutory
distributed to shareholders or other requirements, authorization may come
users in a form that complies with from management or a board of
US GAAP. Financial statements are directors.
considered available to be issued when
they are in a form that complies with
US GAAP and all necessary approvals
have been obtained. SEC registrants
and conduit-bond obligors evaluate
subsequent events through the date the
financial statements are issued, while all
other entities evaluate subsequent
events through the date that the
financial statements are available to
be issued.
US GAAP IFRS
Reissuance of financial If the financial statements are reissued, IAS 10 does not specifically address the
statements events or transactions may have reissuance of financial statements and
occurred that require disclosure in the recognizes only one date through
reissued financial statements to keep which subsequent events are evaluated,
them from being misleading. However, that is, the date that the financial
an entity should not recognize events statements are authorized for issuance,
occurring between the time the even if they are being reissued. As a
financial statements were issued or result, only one date will be disclosed
available to be issued and the time the with respect to the evaluation of
financial statements were reissued subsequent events, and an entity could
unless the adjustment is required by have adjusting subsequent events in
US GAAP or regulatory requirements reissued financial statements.
(e.g., stock splits, discontinued
If financial statements are reissued, the
operations, or the effect of adopting a
date the reissued statements are
new accounting standard authorized for reissuance is disclosed.
retrospectively would give rise to an
adjustment). Entities must disclose
both the date that the financial
statements were originally issued and
the date that they were reissued if the
financial statements were revised due
to an error correction or retrospective
application of US GAAP.
Short-term loans Short-term loans are classified as Shortterm loans refinanced after the
refinanced with long-term if the entity intends to balance sheet date may not be
long-term loans after refinance the loan on a long-term basis reclassified to long-term liabilities
balance sheet date and, prior to issuing the financial unless the entity expected and had the
statements, the entity can discretion to refinance the obligation
demonstrate an ability to refinance the for at least 12 months at the balance
loan by meeting specific criteria. sheet date.
Convergence
No further convergence is planned at this time.
Significant differences
US GAAP IFRS
Scope ASC 850 requires disclosure of all IAS 24 provides a partial exemption
material related party transactions, from the disclosure requirements for
other than compensation transactions between
arrangements, expense allowances and government-related entities as well as
other similar items in the ordinary with the government itself.
course of business.
Convergence
No further convergence is planned at this time
This appendix summarizes key events in the evolution of international accounting standards.
Phase I The early years
1973: International Accounting 1999: IASC Board approved a
Standards Committee (IASC) formed. restructuring that resulted in the current
The IASC was founded to formulate and International Accounting Standards
publish International Accounting Standards Board (IASB). The newly constituted
(IAS) that would improve financial reporting IASB structure comprises: (1) the
and that could be accepted worldwide. IASC Foundation, an independent
In keeping with the original view that organization with 22 trustees who appoint
the IASCs function was to prohibit the IASB members, exercise oversight and
undesirable accounting practices, the raise the funds needed, (2) the IASB (Board),
original IAS permitted several alternative which has 12 full-time, independent board
accounting treatments. members and two part-time board members
with sole responsibility for setting
1994: IOSCO (International Organization
accounting standards, (3) the Standards
of Securities Commissions) completed
Advisory Council and (4) the International
its review of IASC standards and
Financial Reporting Interpretations
communicated its findings to the IASC.
Committee (IFRIC) (replacing the SIC) and
The review identified areas that required
is mandated with interpreting existing IAS
improvement before IOSCO would consider
and IFRS standards, and providing timely
recommending IAS for use in cross-border
guidance on matters not addressed by
listings and offerings.
current standards.
1994: IASC Advisory Council formed to
2000: IOSCO recommended that
oversee the IASC and manage its finances.
multinational issuers be allowed to use
1995: IASC developed its Core Standards IAS in cross-border offerings and listings.
Work Program. IOSCOs Technical
April 2001: IASB assumed
Committee agreed that the Work Program
standard-setting responsibility. The IASB
would result, upon successful completion,
met with representatives from eight national
in IAS comprising a comprehensive core
standard-setting bodies to coordinate
set of standards. The European
agendas and discuss convergence, and
Commission (EC) supported this agreement
adopted existing IAS standards and SIC
between IASC and IOSCO and associated
Interpretations.
itself with the work of the IASC toward
international harmonization of accounting February 2002: IFRIC assumed
standards. responsibility for interpretation of IFRS.
1997: Standing Interpretations Committee
(SIC) established to interpret IAS.
February 2010: SEC reaffirmed its July 2011: SEC staff sponsored a
commitment to IFRS. In February 2010, roundtable to discuss benefits or
the SEC voted unanimously to publish a challenges in potentially incorporating
statement reaffirming its commitment to IFRS into the financial reporting system
the goal of a single set of high-quality global for US issuers. The participants discussed
accounting standards and expressing investors understanding of IFRS, the impact
support for the continued convergence of on smaller public companies and on the
US GAAP and IFRS. The SEC said that after benefits and challenges in potentially
executing a Work Plan to address certain incorporating IFRS into the financial
questions, it would be able to make an reporting system for US issuers.
informed decision in 2011 about the further
November 2011: SEC staff issued
incorporation of IFRS into the US financial
two papers as part of its Work Plan:
reporting system.
An Analysis of IFRS in Practice and
October 2010: SEC issued a Progress A Comparison of US GAAP and IFRS.
Report on its Work Plan. The SEC staff papers provide additional
information for the SEC to review before it
May 2011: SEC staff published a paper
makes its decision.
detailing a possible approach for
incorporating IFRS into the US financial July 2012: SEC staff issued its final
reporting system. The SEC staff said the progress report on its Work Plan for
approach could achieve the goal of a single the Consideration of Incorporating
set of high-quality accounting standards and International Financial Reporting
could minimize the cost and effort needed Standards into the Financial Reporting
to incorporate IFRS into the US financial System for U.S. Issuers (The Final Report).
reporting system. The report summarized what the staff
learned in carrying out the work plan.
Spring through fall 2011: Convergence
schedule delayed. The FASB and the IASB The report does not include a
extend their timetables for completing their recommendation to the Commission about
priority convergence projects beyond their whether or how to incorporate IFRS into the
target of June 2011. The Boards decided US financial reporting system.
to re-expose proposals on revenue
The report notes that the Commission still
recognition and leases, which will result
needs to analyze and consider the threshold
in additional delays.
question whether and, if so, how and
when IFRS should be incorporated into the
US financial reporting system.
As a result, we do not expect a decision
from the Commission before 2013.
Ernst & Young offers a variety of online resources that provide more detail about IFRS as well as
things to consider as you research the potential impact of IFRS on your company.
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