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US GAAP vs. IFRS
The basics
January 2009
Table of contents


2	     Introduction
5	     Financial statement presentation
7	     Interim financial reporting
8	     Consolidations, joint venture accounting and equity
       method investees
11 	   Business combinations
13 	   Inventory
14 	   Long-lived assets
16 	   Intangible assets
18 	   Impairment of long-lived assets, goodwill and
       intangible assets
20 	   Financial instruments
24 	   Foreign currency matters
26 	   Leases
29 	   Income taxes
32 	   Provisions and contingencies
34 	   Revenue recognition
36 	   Share-based payments
38 	   Employee benefits other than share-based payments
40 	   Earnings per share
41 	   Segment reporting
42 	   Subsequent events
43 	   Related parties
44 	   Appendix — The evolution of IFRS
Introduction


It is not surprising that many people who follow    No publication that compares two broad sets of
the development of worldwide accounting             accounting standards can include all differences
standards today might be confused. Convergence      that could arise in accounting for the myriad of
is a high priority on the agendas of both the       business transactions that could possibly occur.
US Financial Accounting Standards Board (FASB)      The existence of any differences — and their
and the International Accounting Standards          materiality to an entity’s financial statements —
Board (IASB) — and “convergence” is a term          depends on a variety of specific factors including:
that suggests an elimination or coming              the nature of the entity, the detailed transactions
together of differences. Yet much is still made     it enters into, its interpretation of the more
of the many differences that exist between          general IFRS principles, its industry practices,
US GAAP as promulgated by the FASB and              and its accounting policy elections where
International Financial Reporting Standards         US GAAP and IFRS offer a choice. This guide
(IFRS) as promulgated by the IASB, suggesting       focuses on those differences most commonly
that the two GAAPs continue to speak                found in present practice and, where applicable,
languages that are worlds apart. This apparent      provides an overview of how and when those
contradiction has prompted many to ask just         differences are expected to converge.
how different are the two sets of standards?
And where differences exist, why do they exist,
and when, if ever, will they be eliminated?
                                                    Why do differences exist?
                                                    As the international standards were developed,
In this guide, “US GAAP v. IFRS: The basics,”       the IASB and its predecessor, the International
we take a top level look into these questions       Accounting Standards Committee (IASC),
and provide an overview, by accounting area,        had the advantage of being able to draw on
both of where the standards are similar and         the latest thinking of standard setters from
also where they diverge. While the US and           around the world. As a result, the international
international standards do contain differences,     standards contain elements of accounting
the general principles, conceptual framework,       standards from a variety of countries. And
and accounting results between them are often       even where an international standard looked
the same or similar, even though the areas of       to an existing US standard as a starting point,
divergence seem to have disproportionately          the IASB was able to take a fresh approach
overshadowed these similarities. We believe         to that standard. In doing so, the IASB could
that any discussion of this topic should not lose   avoid some of the perceived problems in the
sight of the fact that the two sets of standards    FASB standard — for example, exceptions
are generally more alike than different for most    to the standard’s underlying principles
commonly encountered transactions, with IFRS        that had resulted from external pressure
being largely, but not entirely, grounded in the    during the exposure process, or practice
same basic principles as US GAAP.                   difficulties that had emerged subsequent




2                                 US GAAP vs. IFRS The basics
to the standard’s issuance — and attempt to        Will the differences ever be
improve them. Further, as part of its annual       eliminated?
“Improvements Project,” the IASB reviews its
                                                   Both the FASB and IASB (the Boards) publicly
existing standards to enhance their clarity and
                                                   declared their commitment to the convergence
consistency, again taking advantage of more
                                                   of IFRS and US GAAP in the “Norwalk
current thinking and practice.
                                                   Agreement” in 2002, and since that time have
For these reasons, some of the differences         made significant strides toward that goal,
between US GAAP and IFRS are embodied in           including formally updating their agreement in
the standards themselves — that is, they are       2008. Additionally, the United States Securities
intentional deviations from US requirements.       and Exchange Commission (SEC) has been very
                                                   active in this area. For example, within the past
Still other differences have emerged               two years, the SEC eliminated the requirement
through interpretation. As a general rule,         for foreign private issuers to reconcile their
IFRS standards are more broad than their           IFRS results to US GAAP and proposed an
US counterparts, with limited interpretive         updated “Roadmap” addressing the future use
guidance. The IASB has generally avoided           of IFRS in the United States. The Roadmap
issuing interpretations of its own standards,      includes the potential for voluntary adoption
preferring to instead leave implementation         of IFRS by certain large companies as early as
of the principles embodied in its standards        2009 and contemplates mandatory adoption
to preparers and auditors, and its official        for all companies by 2014, 2015 or 2016. The
interpretive body, the International Financial     SEC has stated that continued progress towards
Reporting Interpretations Committee (IFRIC).       convergence is an important milestone that it
While US standards contain underlying              will assess when ultimately deciding on the use
principles as well, the strong regulatory and      of IFRS in the United States.
legal environment in the US market has resulted
in a more prescriptive approach — with far more    Convergence efforts alone will not totally
“bright lines,” comprehensive implementation       eliminate all differences between US GAAP
guidance and industry interpretations.             and IFRS. In fact, differences continue to exist
                                                   in standards for which convergence efforts
Therefore, while some might read the broader       already have been completed, and for which
IFRS standard to require an approach similar       no additional convergence work is planned.
to that contained in its more detailed US          And for those standards currently on the
counterpart, others might not. Differences also    Boards’ convergence agenda, unless the
result from this divergence in interpretation.     words of the standards are totally conformed,
                                                   interpretational differences will almost certainly
                                                   continue to arise.




                                 US GAAP vs. IFRS The basics                                       3
The success of a uniform set of global
accounting standards also will depend on the
willingness of national regulators and industry
groups to cooperate and to avoid issuing
local interpretations of IFRS and guidance
that provides exceptions to IFRS principles.
Some examples of this have already begun to
emerge and could threaten the achievement of
international harmonization.

In planning a possible move to IFRS, it is
important that US companies monitor progress
on the Boards’ convergence agenda to avoid
spending time now analyzing differences that
most likely will be eliminated in the near future.
At present, it is not possible to know the exact
extent of convergence that will exist at the
time US public companies may be required to
adopt the international standards. However,
that should not stop preparers, users and
auditors from gaining a general understanding
of the similarities and key differences between
IFRS and US GAAP, as well as the areas
presently expected to converge. We hope you
find this guide a useful tool for that purpose.




January 2009




4                                  US GAAP vs. IFRS The basics
Financial statement presentation


Similarities                                             financial statements. Further, both frameworks
                                                         require that the financial statements be
There are many similarities between US GAAP
                                                         prepared on the accrual basis of accounting
and IFRS relating to financial statement
                                                         (with the exception of the cash flows statement)
presentation. For example, under both
                                                         except for rare circumstances. Both GAAPs
frameworks, the components of a complete set
                                                         have similar concepts regarding materiality and
of financial statements include: balance sheet,
                                                         consistency that entities have to consider in
income statement, other comprehensive income
                                                         preparing their financial statements. Differences
for US GAAP or statement of recognized income
                                                         between the two tend to arise in the level of
and expense (SORIE) for IFRS, statement of
                                                         specific guidance.
cash flows, and accompanying notes to the


Significant differences
                          US GAAP                                     IFRS
Financial periods         Generally, comparative financial            Comparative information must be
required                  statements are presented; however, a        disclosed in respect of the previous
                          single year may be presented in certain     period for all amounts reported in the
                          circumstances. Public companies must        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               IAS 1 Presentation of Financial
and income statement      US GAAP to prepare the balance sheet        Statements does not prescribe a
                          and income statement in accordance          standard layout, but includes a list
                          with a specific layout; however, public     of minimum items. These minimum
                          companies must follow the detailed          items are less prescriptive than the
                          requirements in Regulation S-X.             requirements in Regulation S-X.
Presentation of debt      Debt for which there has been a             Debt associated with a covenant
as current versus non-    covenant violation may be presented         violation must be presented as current
current in the balance    as non-current if a lender agreement to     unless the lender agreement was
sheet                     waive the right to demand repayment         reached prior to the balance sheet date.
                          for more than one year exists prior to      Deferred taxes are presented as non-
                          the issuance of the financial statements.   current. (Note: In the joint convergence
                          Deferred taxes are presented as             project on income taxes, IFRS is
                          current or non-current based on the         expected to converge with US GAAP.)
                          nature of the related asset or liability.
Income statement —        SEC registrants are required to present     Entities may present expenses based on
classification of         expenses based on function (for             either function or nature (for example,
expenses                  example, cost of sales, administrative).    salaries, depreciation). However, if
                                                                      function is selected, certain disclosures
                                                                      about the nature of expenses must be
                                                                      included in the notes.



                                    US GAAP vs. IFRS The basics                                                   5
US GAAP                                   IFRS
Income statement —        Restricted to items that are both         Prohibited.
extraordinary items       unusual and infrequent.
Income statement —        Discontinued operations classification    Discontinued operations classification
discontinued operations   is for components held for sale or to     is for components held for sale or to be
presentation              be disposed of, provided that there       disposed of that are either a separate
                          will not be significant continuing cash   major line of business or geographical
                          flows or involvement with the disposed    area or a subsidiary acquired
                          component.                                exclusively with an intention to resale.
Changes in equity         Present all changes in each caption of    At a minimum, present components
                          stockholders’ equity in either a footnote related to “recognized income and
                          or a separate statement.                  expense” as part of a separate
                                                                    statement (referred to as the SORIE if it
                                                                    contains no other components). Other
                                                                    changes in equity either disclosed in the
                                                                    notes, or presented as part of a single,
                                                                    combined statement of all changes in
                                                                    equity (in lieu of the SORIE).
Disclosure of             SEC regulations define certain key        Certain traditional concepts such as
performance measures      measures and require the presentation     “operating profit” are not defined;
                          of certain headings and subtotals.        therefore, diversity in practice exists
                          Additionally, public companies are        regarding line items, headings and
                          prohibited from disclosing non-GAAP       subtotals presented on the income
                          measures in the financial statements      statement when such presentation is
                          and accompanying notes.                   relevant to an understanding of the
                                                                    entity’s financial performance.


Convergence                                            face of the financial statements, and may
                                                       ultimately result in significant changes in the
In April 2004, the FASB and the IASB (the
                                                       current presentation format of the financial
Boards) agreed to undertake a joint project
                                                       statements under both GAAPs.
on financial statement presentation. As part
of “Phase A” of the project, the IASB issued           In September 2008, the Boards issued
a revised IAS 1 in September 2007 (with an             proposed amendments to FAS 144 and IFRS 5
effective date for annual reporting periods            to converge the definition of discontinued
ending after January 1, 2009) modifying                operations. Under the proposals, a discontinued
the requirements of the SORIE within IAS 1             operation would be a component of an entity
and bringing it largely in line with the FASB’s        that is either (1) an operating segment (as
statement of other comprehensive income. As            defined in FAS 131 and IFRS 8, respectively)
part of “Phase B,” the Boards each issued an           held for sale or that has been disposed of, or
initial discussion document in October 2008,           (2) a business (as defined in FAS 141(R)) that
with comments due by April 2009. This phase            meets the criteria to be classified as held for
of the project addresses the more fundamental          sale on acquisition.
issues for presentation of information on the


6                                   US GAAP vs. IFRS The basics
Interim financial reporting


Similarities                                            financial statements (which are similar but not
                                                        identical) and provide for comparable disclosure
APB 28 and IAS 34 (both entitled Interim
                                                        requirements. Neither standard mandates
Financial Reporting) are substantially similar
                                                        which entities are required to present interim
with the exception of the treatment of certain
                                                        financial information, that being the purview
costs as described below. Both require an
                                                        of local securities regulators. For example,
entity to use the same accounting policies
                                                        US public companies must follow the SEC’s
that were in effect in the prior year, subject
                                                        Regulation S-X for the purpose of preparing
to adoption of new policies that are disclosed.
                                                        interim financial information.
Both standards allow for condensed interim

Significant difference
                           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    discrete reporting period. A cost that
                           a result, certain costs that benefit     does not meet the definition of an asset
                           more than one interim period may         at the end of an interim period is not
                           be allocated among those periods,        deferred and a liability recognized at an
                           resulting in deferral or accrual of      interim reporting date must represent
                           certain costs. For example, certain      an existing obligation. For example,
                           inventory cost variances may be          inventory cost variances that do not
                           deferred on the basis that the interim   meet the definition of an asset cannot
                           statements are an integral part of an    be deferred. However, income taxes
                           annual period.                           are accounted for based on an annual
                                                                    effective tax rate (similar to US GAAP).


Convergence
As part of their joint Financial Statement
Presentation project, the FASB will address
presentation and display of interim financial
information in US GAAP, and the IASB may
reconsider the requirements of IAS 34. This
phase of the Financial Statement Presentation
project has not commenced.




                                    US GAAP vs. IFRS The basics                                                 7
Consolidations, joint venture accounting and
equity method investees

Similarities                                            for all of the entities within a consolidated
                                                        group, with certain exceptions under US GAAP
The principle guidance for consolidation
                                                        (for example, a subsidiary within a specialized
of financial statements under US GAAP is
                                                        industry may retain the specialized accounting
ARB 51 Consolidated Financial Statements
                                                        policies in consolidation). Under both GAAPs,
(as amended by FAS 160 Noncontrolling
                                                        the consolidated financial statements of the
Interests in Consolidated Financial Statements)
                                                        parent and its subsidiaries may be based
and FAS 94 Consolidation of All Majority-
                                                        on different reporting dates as long as the
Owned Subsidiaries; while IAS 27 (Amended)
                                                        difference is not greater than three months.
Consolidated and Separate Financial
                                                        However, under IFRS a subsidiary’s financial
Statements provides the guidance under
                                                        statements should be as of the same date as
IFRS. Special purpose entities are addressed
                                                        the financial statements of the parent’s unless
in FIN 46 (Revised) Consolidation of Variable
                                                        is it impracticable to do so.
Interest Entities and SIC 12 Consolidation —
Special Purpose Entities in US GAAP and IFRS            An equity investment that gives an investor
respectively. Under both US GAAP and IFRS,              significant influence over an investee (referred
the determination of whether or not entities            to as “an associate” in IFRS) is considered an
are consolidated by a reporting enterprise is           equity-method investment under both US GAAP
based on control, although differences exist            (APB 18 The Equity Method of Accounting for
in the definition of control. Generally, under          Investments in Common Stock) and IFRS (IAS 28
both GAAPs all entities subject to the control of       Investments in Associates), if the investee is
the reporting enterprise must be consolidated           not consolidated. Further, the equity method of
(note that there are limited exceptions in              accounting for such investments, if applicable,
US GAAP in certain specialized industries).             generally is consistent under both GAAPs.
Further, uniform accounting policies are used

Significant differences
                         US GAAP                                       IFRS
Consolidation model      Focus is on controlling financial             Focus is on the concept of the power
                         interests. All entities are first evaluated   to control, with control being the
                         as potential variable interest entities       parent’s ability to govern the financial
                         (VIEs). If a VIE, FIN 46 (Revised)            and operating policies of an entity to
                         guidance is followed (below). Entities        obtain benefits. Control presumed to
                         controlled by voting rights are               exist if parent owns greater than 50%
                         consolidated as subsidiaries, but             of the votes, and potential voting rights
                         potential voting rights are not included      must be considered. Notion of “de facto
                         in this consideration. The concept of         control” must also be considered.
                         “effective control” exists, but is rarely
                         employed in practice.




8                                  US GAAP vs. IFRS The basics
US GAAP                                      IFRS
Special purpose entities    FIN 46 (Revised) requires the primary        Under SIC 12, SPEs (entities created to
(SPE)                       beneficiary (determined based on the         accomplish a narrow and well-defined
                            consideration of economic risks and          objective) are consolidated when the
                            rewards) to consolidate the VIE.             substance of the relationship indicates
                                                                         that an entity controls the SPE.
Preparation of              Required, although certain industry-         Generally required, but there is a limited
consolidated financial      specific exceptions exist (for example,      exemption from preparing consolidated
statements — general        investment companies).                       financial statements for a parent
                                                                         company that is itself a wholly-owned
                                                                         subsidiary, or is a partially-owned
                                                                         subsidiary if certain conditions are met.
Preparation of              The effects of significant events            The effects of significant events
consolidated financial      occurring between the reporting dates        occurring between the reporting dates
statements — different      when different dates are used are            when different dates are used are
reporting dates of parent   disclosed in the financial statements.       adjusted for in the financial statements.
and subsidiary(ies)
Presentation of             Presented outside of equity on the           Presented as a separate component in
noncontrolling or           balance sheet (prior to the adoption of      equity on the balance sheet.
“minority” interest         FAS 160).
Equity-method               FAS 159 The Fair Value Option for            IAS 28 requires investors (other than
investments                 Financial Assets and Financial Liabilities   venture capital organizations, mutual
                            gives entities the option to account         funds, unit trusts, and similar entities)
                            for their equity-method investments          to use the equity-method of accounting
                            at fair value. For those equity-method       for such investments in consolidated
                            investments for which management             financial statements. If separate
                            does not elect to use the fair value         financial statements are presented
                            option, the equity method of accounting      (that is, those presented by a parent or
                            is required.                                 investor), subsidiaries and associates
                                                                         can be accounted for at either cost or
                            Uniform accounting policies between
                                                                         fair value.
                            investor and investee are not required.
                                                                         Uniform accounting policies between
                                                                         investor and investee are required.
Joint ventures              Generally accounted for using the            IAS 31 Investments in Joint Ventures
                            equity-method of accounting, with the        permits either the proportionate
                            limited exception of unincorporated          consolidation method or the equity
                            entities operating in certain industries     method of accounting.
                            which may follow proportionate
                            consolidation.




                                      US GAAP vs. IFRS The basics                                                     9
Convergence                                           At the time of this publication, the FASB is
                                                      proposing amendments to FIN 46 (Revised).
As part of their joint project on business
                                                      Additionally, the IASB is working on a
combinations, the FASB issued FAS 160
                                                      consolidation project that would replace IAS 27
(effective for fiscal years beginning on or after
                                                      (amended) and SIC 12 and is expected to provide
December 15, 2008) and the IASB amended
                                                      for a single consolidation model within IFRS.
IAS 27 (effective for fiscal years beginning
                                                      It is currently unclear whether these projects
on or after July 1, 2009, with early adoption
                                                      will result in additional convergence, and future
permitted), thereby eliminating substantially all
                                                      developments should be monitored.
of the differences between US GAAP and IFRS
pertaining to noncontrolling interests, outside
of the initial accounting for the noncontrolling
interest in a business combination (see the
Business Combinations section). In addition,
the IASB recently issued an exposure draft
that proposes the elimination of proportionate
consolidation for joint ventures.




10                                  US GAAP vs. IFRS The basics
Business combinations


Similarities                                            assets, liabilities and noncontrolling interests of
                                                        the acquired entity are measured (as described
The issuance of FAS 141(R) and IFRS 3(R)
                                                        in the table below, IFRS 3(R) provides an
(both entitled Business Combinations),
                                                        alternative to measuring noncontrolling interest
represent the culmination of the first major
                                                        at fair value), with limited exceptions. Even
collaborative convergence project between the
                                                        though the new standards are substantially
IASB and the FASB. Pursuant to FAS 141(R)
                                                        converged, certain differences will exist once
and IFRS 3(R), all business combinations are
                                                        the new standards become effective. The new
accounted for using the acquisition method.
                                                        standards will be effective for annual periods
Under the acquisition method, upon obtaining
                                                        beginning on or after December 15, 2008,
control of another entity, the underlying
                                                        and July 1, 2009, for companies following
transaction should be measured at fair value,
                                                        US GAAP and IFRS, respectively.
and this should be the basis on which the

Significant differences
                          US GAAP                                      IFRS
Measurement of            Noncontrolling interest is measured          Noncontrolling interest is measured
noncontrolling interest   at fair value, which includes the            either at fair value including goodwill or
                          noncontrolling interest’s share of           its proportionate share of the fair value
                          goodwill.                                    of the acquiree’s identifiable net assets,
                                                                       exclusive of goodwill.
Assets and liabilities    Initial Recognition                          Initial Recognition
arising from              Distinguishes between contractual            Contingent liabilities are recognized
contingencies             and noncontractual contingencies.            as of the acquisition date if there is
                          Contractual contingencies are measured       a present obligation that arises from
                          at fair value at the acquisition date,       past events and its fair value can be
                          while noncontractual contingencies           measured reliably. Contingent assets
                          are recognized at fair value at the          are not recognized.
                          acquisition date only if it is more likely
                          than not that the contingency meets the
                          definition of an asset or liability.
                          Subsequent Measurement                       Subsequent Measurement
                          Contingently liabilities are                 Contingent liabilities are subsequently
                          subsequently measured at the higher          measured at the higher of its acquisition-
                          of its acquisition-date fair value, or       date fair value less, if appropriate,
                          the amount that would be recognized          cumulative amortization recognized in
                          if applying FAS 5, Accounting for            accordance with IAS 18, Revenue, or
                          Contingencies. (See “Provisions and          the amount that would be recognized if
                          contingencies” for differences between       applying IAS 37, Provisions, Contingent
                          FAS 5 and IAS 37.)                           Liabilities and Contingent Assets..




                                    US GAAP vs. IFRS The basics                                                 11
US GAAP                                   IFRS
Acquiree operating        If the terms of an acquiree operating     Separate recognition of an intangible
leases                    lease are favorable or unfavorable        asset or liability is required only if the
                          relative to market terms, the acquirer    acquiree is a lessee. If the acquiree is
                          recognizes an intangible asset or         the lessor, the terms of the lease are
                          liability, respectively, regardless of    taken into account in estimating the fair
                          whether the acquiree is the lessor or     value of the asset subject to the lease
                          the lessee.                               – separate recognition of an intangible
                                                                    asset or liability is not required.
Combination of entities   Accounted for in a manner similar to a    Outside the scope of IFRS 3R. In
under common control      pooling of interests (historical cost).   practice, either follow an approach
                                                                    similar to US GAAP or apply the
                                                                    purchase method if there is substance
                                                                    to the transaction.

Other differences may arise due to different           Convergence
accounting requirements of other existing
                                                       No further convergence is planned at this
US GAAP-IFRS literature (for example, identifying
                                                       time. Note, however, that as of the date of this
the acquirer, definition of control, definition of
                                                       publication, the FASB has issued a proposed
fair value, replacement of share-based payment
                                                       FSP that would change the accounting for
awards, initial classification and subsequent
                                                       preacquisition contingencies under FAS 141(R).
measurement of contingent consideration, initial
                                                       The proposed FSP proposes a model that is
recognition and measurement of income taxes,
                                                       very similar to the existing requirements of
and initial recognition and measurement of
                                                       FAS 141 for purposes of initial recognition.
employee benefits).
                                                       Assets and liabilities measured at fair value
                                                       would continue to be subject to subsequent
                                                       measurement guidance similar to that currently
                                                       described in FAS 141(R).




12                                  US GAAP vs. IFRS The basics
Inventory


Similarities                                            for cost measurement, such as standard cost
                                                        method or retail method, are similar under
ARB 43 Chapter 4 Inventory Pricing and IAS
                                                        both US GAAP and IFRS. Further, under both
2 Inventories are both based on the principle
                                                        GAAPs the cost of inventory includes all direct
that the primary basis of accounting for
                                                        expenditures to ready inventory for sale,
inventory is cost. Both define inventory as
                                                        including allocable overhead, while selling
assets held for sale in the ordinary course of
                                                        costs are excluded from the cost of inventories,
business, in the process of production for such
                                                        as are most storage costs and general
sale, or to be consumed in the production of
                                                        administrative costs.
goods or services. The permitted techniques

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 (best estimate
                          replacement cost as long as market is       of the net amounts inventories are
                          not greater than net realizable value       expected to realize. This amount may
                          (estimated selling price less reasonable    or may not equal fair value).
                          costs of completion and sale) and
                          is not less than net realizable value
                          reduced by a normal sales margin.
Reversal of inventory     Any write-downs of inventory to the         Previously recognized impairment
write-downs               lower of cost or market create a new        losses are reversed, up to the amount
                          cost basis that subsequently cannot be      of the original impairment loss when
                          reversed.                                   the reasons for the impairment no
                                                                      longer exist.
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          RIM. Reduction of the carrying cost of
(RIM)                     the carrying cost of inventory to net       inventory to below the lower of cost or
                          realizable value, less an allowance for     net realizable value is not allowed.
                          an approximately normal profit margin,
                          which may be less than both original
                          cost and net realizable value.

Convergence                                             abnormal amounts of idle facility expense,
                                                        freight, handling costs and spoilage. At present,
In November 2004, the FASB issued FAS 151
                                                        there are no other ongoing convergence efforts
Inventory Costs to address a narrow difference
                                                        with respect to inventory.
between US GAAP and IFRS related to the
accounting for inventory costs, in particular,


                                    US GAAP vs. IFRS The basics                                                 13
Long-lived assets


Similarities                                          between US GAAP and IFRS in the specific
                                                      costs and assets that are included within
Although US GAAP does not have a
                                                      these categories as well as the requirement to
comprehensive standard that addresses long-
                                                      capitalize these costs.
lived assets, its definition of property, plant and
equipment is similar to IAS 16 Property, Plant
and Equipment, which addresses tangible assets        Depreciation
held for use that are expected to be used for         Depreciation of long-lived assets is required
more than one reporting period. Other concepts        on a systematic basis under both accounting
that are similar include the following:               models. FAS 154 Accounting Changes and
                                                      Error Corrections and IAS 8 Accounting
Cost                                                  Policies, Changes in Accounting Estimates
                                                      and Error Corrections both treat changes
Both accounting models have similar recognition
                                                      in depreciation method, residual value and
criteria, requiring that costs be included in the
                                                      useful economic life as a change in accounting
cost of the asset if future economic benefits
                                                      estimate requiring prospective treatment.
are probable and can be reliably measured. The
costs to be capitalized under both models are
similar. Neither model allows the capitalization      Assets held for sale
of start-up costs, general administrative and         Assets held for sale are discussed in FAS
overhead costs or regular maintenance.                144 and IFRS 5 Non-Current Assets Held for
However, both US GAAP and IFRS require that           Sale and Discontinued Operations, with both
the costs of dismantling an asset and restoring       standards having similar held for sale criteria.
its site (that is, the costs of asset retirement      Under both standards, the asset is measured
under FAS 143 Accounting for Asset Retirement         at the lower of its carrying amount or fair
Obligations or IAS 37 Provisions, Contingent          value less costs to sell; the assets are not
Liabilities and Contingent Assets) be included        depreciated and are presented separately on
in the cost of the asset. Both models require         the face of the balance sheet. Exchanges of
a provision for asset retirement costs to be          nonmonetary similar productive assets are also
recorded when there is a legal obligation,            treated similarly under APB 29 Accounting for
although IFRS requires provision in other             Nonmonetary Exchanges as amended by FAS
circumstances as well.                                153 Accounting for Nonmonetary Transactions
                                                      and IAS 16, both of which allow gain/loss
Capitalized interest                                  recognition if the exchange has commercial
                                                      substance and the fair value of the exchange
FAS 34 Capitalization of Interest and IAS 23
                                                      can be reliably measured.
Borrowing Costs address the capitalization
of borrowing costs (for example, interest
costs) directly attributable to the acquisition,
construction or production of a qualifying
asset. Qualifying assets are generally defined
similarly under both accounting models.
However, there are significant differences


14                                  US GAAP vs. IFRS The basics
Significant differences
                          US GAAP                                   IFRS
Revaluation of assets     Revaluation not permitted.                Revaluation is a permitted accounting
                                                                    policy election for an entire class of
                                                                    assets, requiring revaluation to fair
                                                                    value on a regular basis.
Depreciation of asset     Component depreciation permitted but      Component depreciation required if
components                not common.                               components of an asset have differing
                                                                    patterns of benefit.
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. Borrowing costs
                          funds generally cannot offset interest    are offset by investment income earned
                          costs incurred during the period.         on those borrowings.
                          For borrowings associated with a          For borrowings associated with a
                          specific qualifying asset, borrowing      specific qualifying asset, actual
                          costs equal to the weighted average       borrowing costs are capitalized.
                          accumulated expenditures times the
                          borrowing rate are capitalized.
Costs of a major          Multiple accounting models have           Costs that represent a replacement
overhaul                  evolved in practice, including: expense   of a previously identified component
                          costs as incurred, capitalize costs and   of an asset are capitalized if future
                          amortize through the date of the next     economic benefits are probable and
                          overhaul, or follow the IFRS approach.    the costs can be reliably measured.
Investment property       Investment property is not separately    Investment property is separately
                          defined and, therefore, is accounted for defined in IAS 40 as an asset held to
                          as held for use or held for sale.        earn rent or for capital appreciation
                                                                   (or both) and may include property
                                                                   held by lessees under a finance/
                                                                   operating lease. Investment property
                                                                   may be accounted for on a historical
                                                                   cost basis or on a fair value basis as an
                                                                   accounting policy election. Capitalized
                                                                   operating lease classified as investment
                                                                   property must be accounted for using
                                                                   the fair value model.

Other differences include: (i) hedging gains           Convergence
and losses related to the purchase of assets,
                                                       No further convergence is planned at this time.
(ii) constructive obligations to retire assets,
(iii) the discount rate used to calculate asset
retirement costs, and (iv) the accounting for
changes in the residual value.


                                    US GAAP vs. IFRS The basics                                              15
Intangible assets


Similarities                                           internally developed intangibles are not
                                                       recognized as an asset under either FAS 142
The definition of intangible assets as non-
                                                       or IAS 38. Moreover, internal costs related
monetary assets without physical substance is
                                                       to the research phase of research and
the same under both US GAAP’s FAS 141(R)
                                                       development are expensed as incurred under
and FAS 142 Goodwill and Other Intangible
                                                       both accounting models.
Assets and the IASB’s IFRS 3(R) and IAS 38
Intangible Assets. The recognition criteria            Amortization of intangible assets over their
for both accounting models require that                estimated useful lives is required under both
there be probable future economic benefits             US GAAP and IFRS, with one minor exception in
and costs that can be reliably measured.               FAS 86 Accounting for the Costs of Computer
However, some costs are never capitalized              Software to be Sold, Leased or Otherwise
as intangible assets under both models, such           Marketed related to the amortization of
as start-up costs. Goodwill is recognized only         computer software assets. In both, if there is
in a business combination in accordance                no foreseeable limit to the period over which
with FAS 141(R) and IFRS 3(R). In general,             an intangible asset is expected to generate
intangible assets that are acquired outside            net cash inflows to the entity, the useful life is
of a business combination are recognized at            considered to be indefinite and the asset is not
fair value. With the exception of development          amortized. Goodwill is never amortized.
costs (addressed in the following table),

Significant differences
                        US GAAP                                       IFRS
Development costs       Development costs are expensed as             Development costs are capitalized
                        incurred unless addressed by a separate       when technical and economic feasibility
                        standard. Development costs related           of a project can be demonstrated
                        to computer software developed for            in accordance with specific criteria.
                        external use are capitalized once             Some of the stated criteria include:
                        technological feasibility is established in   demonstrating technical feasibility,
                        accordance with specific criteria (FAS        intent to complete the asset, and ability
                        86). In the case of software developed        to sell the asset in the future, as well as
                        for internal use, only those costs incurred   others. Although application of these
                        during the application development stage      principals may be largely consistent
                        (as defined in SOP 98-1 Accounting            with FAS 86 and SOP 98-1, there
                        for the Costs of Computer Software            is no separate guidance addressing
                        Developed or Obtained for Internal Use)       computer software development costs.
                        may be capitalized.
Advertising costs       Advertising and promotional costs are         Advertising and promotional costs are
                        either expensed as incurred or expensed       expensed as incurred. A prepayment
                        when the advertising takes place for the      may be recognized as an asset only
                        first time (policy choice). Direct response   when payment for the goods or
                        advertising may be capitalized if the         services is made in advance of the
                        specific criteria in SOP 93-07 Reporting      entity’s having access to the goods or
                        on Advertising Costs are met.                 receiving the services.



16                                US GAAP vs. IFRS The basics
US GAAP                                    IFRS
Revaluation              Revaluation is not permitted               Revaluation to fair value of intangible
                                                                    assets other than goodwill is a
                                                                    permitted accounting policy election
                                                                    for a class of intangible assets. Because
                                                                    revaluation requires reference to an
                                                                    active market for the specific type of
                                                                    intangible, this is relatively uncommon
                                                                    in practice.


Convergence                                             the 2008 MOU, the FASB indicated that it will
                                                        consider in the future whether to undertake a
While the convergence of standards on intangible
                                                        project to eliminate differences in the accounting
assets was part of the 2006 “Memorandum of
                                                        for research and development costs by fully
Understanding” (MOU) between the FASB and
                                                        adopting IAS 38 at some point in the future.
the IASB, both boards agreed in 2007 not to
add this project to their agenda. However, in




                                  US GAAP vs. IFRS The basics                                              17
Impairment of long-lived assets, goodwill and
intangible assets

Similarities                                             that an asset found to be impaired be written
                                                         down and an impairment loss recognized. FAS
Both US GAAP and IFRS contain similarly
                                                         142, FAS 144 Accounting for the Impairment
defined impairment indicators for assessing the
                                                         or Disposal of Long-Lived Assets, and IAS 36
impairment of long-lived assets. Both standards
                                                         Impairment of Assets apply to most long-lived
require goodwill and intangible assets with
                                                         and intangible assets, although some of the
indefinite lives to be reviewed at least annually
                                                         scope exceptions listed in the standards differ.
for impairment and more frequently if
                                                         Despite the similarity in overall objectives,
impairment indicators are present. Long-lived
                                                         differences exist in the way in which impairment
assets are not tested annually, but rather
                                                         is reviewed, recognized and measured.
when there are indicators of impairment. The
impairment indicators in US GAAP and IFRS
are similar. Additionally, both GAAPs require

Significant differences
                           US GAAP                                     IFRS
Method of determining      Two-step approach requires a                One-step approach requires that
impairment — long-lived    recoverability test be performed            impairment testing be performed if
assets                     first (carrying amount of the asset         impairment indicators exist.
                           is compared to the sum of future
                           undiscounted cash flows generated
                           through use and eventual disposition).
                           If it is determined that the asset is not
                           recoverable, impairment testing must
                           be performed.
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
                           FAS 157.                                    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). (Note
                                                                       that the definition of fair value in
                                                                       IFRS has certain differences from the
                                                                       definition in FAS 157.)
Allocation of goodwill     Goodwill is allocated to a reporting        Goodwill is allocated to a cash-
                           unit, which is an operating segment or      generating unit (CGU) or group of
                           one level below an operating segment        CGUs which represents the lowest level
                           (component).                                within the entity at which the goodwill
                                                                       is monitored for internal management
                                                                       purposes and cannot be larger than
                                                                       an operating segment as defined in
                                                                       IFRS 8, Operating Segments.




18                                   US GAAP vs. IFRS The basics
US GAAP                                       IFRS
Method of determining      Two-step approach requires a                  One-step approach requires that
impairment — goodwill      recoverability test to be performed           an impairment test be done at the
                           first at the reporting unit level (carrying   cash generating unit (CGU) level by
                           amount of the reporting unit is               comparing the CGU’s carrying amount,
                           compared to the reporting unit fair           including goodwill, with its recoverable
                           value). If the carrying amount of the         amount.
                           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 CGU’s 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              The amount by which the carrying
calculation — indefinite   value of the asset exceeds its fair value.    value of the asset exceeds its
life intangible assets                                                   recoverable amount.
Reversal of loss           Prohibited for all assets to be held and      Prohibited for goodwill. Other long-
                           used.                                         lived assets must be reviewed annually
                                                                         for reversal indicators. If appropriate,
                                                                         loss may be reversed up to the newly
                                                                         estimated recoverable amount, not
                                                                         to exceed the initial carrying amount
                                                                         adjusted for depreciation.


Convergence
Impairment is one of the short-term
convergence projects agreed to by the FASB
and IASB in their 2006 MOU. However, as part
of their 2008 MOU, the boards agreed to defer
work on completing this project until their other
convergence projects are complete.




                                     US GAAP vs. IFRS The basics                                                19
Financial instruments


Similarities                                             and Financial Liabilities. IFRS guidance for
                                                         financial instruments, on the other hand, is
The US GAAP guidance for financial
                                                         limited to three standards (IAS 32 Financial
instruments is contained in several standards.
                                                         Instruments: Presentation, IAS 39 Financial
Those standards include, among others, FAS
                                                         Instruments: Recognition and Measurement,
65 Accounting for Certain Mortgage Banking
                                                         and IFRS 7 Financial Instruments: Disclosures).
Activities, FAS 107 Disclosures about Fair Value
                                                         Both GAAPs require financial instruments to be
of Financial Instruments, FAS 114 Accounting
                                                         classified into specific categories to determine
by Creditors for Impairment of a Loan, FAS115
                                                         the measurement of those instruments,
Accounting for Certain Investments in Debt
                                                         clarify when financial instruments should
and Equity Securities, FAS 133 Accounting for
                                                         be recognized or derecognized in financial
Derivative Instruments and Hedging Activities,
                                                         statements, and require the recognition of
FAS 140 Accounting for Transfers and Servicing
                                                         all derivatives on the balance sheet. Hedge
of Financial Assets and Extinguishments of
                                                         accounting and use of a fair value option is
Liabilities, FAS 150 Accounting for Certain
                                                         permitted under both. Each GAAP also requires
Financial Instruments with Characteristics of
                                                         detailed disclosures in the notes to financial
both Liabilities and Equity, FAS 155 Accounting
                                                         statements for the financial instruments
for Certain Hybrid Financial Instruments,
                                                         reported in the balance sheet.
FAS 157 Fair Value Measurements, and FAS 159
The Fair Value Option for Financial Assets

Significant differences
                           US GAAP                                    IFRS
Fair value measurement     One measurement model whenever             Various IFRS standards use slightly
                           fair value is used (with limited           varying wording to define fair value.
                           exceptions). Fair value is the price       Generally fair value represents
                           that would be received to sell an asset    the amount that an asset could be
                           or paid to transfer a liability in an      exchanged for, or a liability settled
                           orderly transaction between market         between knowledgeable, willing parties
                           participants at the measurement date.      in an arm’s length transaction.
                           Fair value is an exit price, which may
                           differ from the transaction (entry)        At inception, transaction (entry) price
                           price.                                     generally is considered fair value.
Use of fair value option   Financial instruments can be measured      Financial instruments can be measured
                           at fair value with changes in fair value   at fair value with changes in fair value
                           reported through net income, except        reported through net income provided
                           for specific ineligible financial assets   that certain criteria, which are more
                           and liabilities.                           restrictive than under US GAAP, are met.




20                                   US GAAP vs. IFRS The basics
US GAAP                                       IFRS
Day one gains and losses Entities are not precluded from         Day one gains and losses are
                         recognizing day one gains and losses    recognized only when all inputs to the
                         on financial instruments reported at    measurement model are observable.
                         fair value even when all inputs to the
                         measurement model are not observable.
                         For example, a day one gain or loss may
                         occur when the transaction occurs in a
                         market that differs from the reporting
                         entity’s exit market.
Debt vs. equity            US GAAP specifically identifies certain       Classification of certain instruments with
classification             instruments with characteristics of           characteristics of both debt and equity
                           both debt and equity that must be             focuses on the contractual obligation to
                           classified as liabilities.                    deliver cash, assets or an entity’s own
                                                                         shares. Economic compulsion does not
                                                                         constitute a contractual obligation.
                           Certain other contracts that are indexed      Contracts that are indexed to, and
                           to, and potentially settled in, a company’s   potentially settled in, a company’s own
                           own stock may be classified as equity         stock are classified as equity when
                           if they: (1) require physical settlement      settled by delivering a fixed number of
                           or net-share settlement, or (2) give the      shares for a fixed amount of cash.
                           issuer a choice of net-cash settlement or
                           settlement in its own shares.
Compound (hybrid)          Compound (hybrid) financial instruments       Compound (hybrid) financial
financial instruments      (for example, convertible bonds) are not      instruments are required to be split
                           split into debt and equity components         into a debt and equity component and,
                           unless certain specific conditions are        if applicable, a derivative component.
                           met, but they may be bifurcated into          The derivative component may be
                           debt and derivative components, with          subjected to fair value accounting.
                           the derivative component subjected to
                           fair value accounting.
Impairment recognition —   Declines in fair value below cost may         Generally, only evidence of credit
Available for Sale (AFS)   result in an impairment loss being            default results in an impairment being
financial instruments      recognized in the income statement            recognized in the income statement of
                           on an AFS debt security due solely to         an AFS debt instrument.
                           a change in interest rates (risk-free or
                                                                         Impairment losses recognized through
                           otherwise) if the entity does not have
                                                                         the income statement for available-
                           the positive ability and intent to hold
                                                                         for-sale equity securities cannot be
                           the asset for a period of time sufficient
                                                                         reversed through the income statement
                           to allow for any anticipated recovery in
                                                                         for future recoveries. However,
                           fair value.
                                                                         impairment losses for debt instruments
                           When an impairment is recognized              classified as available-for-sale may be
                           through the income statement, a               reversed through the income statement
                           new cost basis in the investment is           if the fair value of the asset increases in
                           established. Such losses can not be           a subsequent period and the increase
                           reversed for any future recoveries.           can be objectively related to an event
                                                                         occurring after the impairment loss
                                                                         was recognized.


                                     US GAAP vs. IFRS The basics                                                   21
US GAAP                                       IFRS
Hedge effectiveness —      Permitted.                                    Not permitted.
shortcut method for
interest rate swaps
Hedging a component        The risk components that may be               Allows entities to hedge components
of a risk in a financial   hedged are specifically defined by the        (portions) of risk that give rise to
instrument                 literature, with no additional flexibility.   changes in fair value.
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, depending           liabilities, except for certain reclassified
                        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.
Derecognition of           Derecognition of financial assets (sales    Derecognition is based on a mixed
financial assets           treatment) occurs when effective            model that considers both transfer of
                           control has been surrendered over           risks and rewards and control. If the
                           the financial assets. Control has been      transferor has neither retained nor
                           surrendered only if certain specific        transferred substantially all of the
                           criteria have been met, including           risks and rewards, there is then an
                           evidence of legal isolation.                evaluation of the transfer of control.
                           Special rules apply for transfers involving Control is considered to be surrendered
                                                                       if the transferee has the practical ability
                           “qualifying” special-purpose entities.
                                                                       to unilaterally sell the transferred asset
                                                                       to a third party, without restrictions.
                                                                       There is no legal isolation test
                                                                         The concept of a qualifying special-
                                                                         purpose entity does not exist.
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.

Other differences include: (i) application of              sale exception, (v) foreign exchange gain and/
fair value measurement principles, including               or losses on AFS investments, (vi) recognition
use of prices obtained in ‘principal’ versus               of basis adjustments when hedging future
‘most advantageous’ markets, (ii) definitions              transactions, (vii) macro hedging, (viii) hedging
of a derivative and embedded derivative,                   net investments, (ix) impairment criteria for
(iii) cash flow hedge — basis adjustment and               equity investments, (x) puttable minority interest
effectiveness testing, (iv) normal purchase and            and (xi) netting and offsetting arrangements.




22                                    US GAAP vs. IFRS The basics
Convergence                                           The FASB and the IASB have separate, but
                                                      related, projects on reducing complexity in
The IASB is currently working on a project to
                                                      this area, with both Boards issuing documents
establish a single source of guidance for all fair
                                                      in 2008. The FASB issued an exposure draft
value measurements required or permitted
                                                      directed at simplifying hedge accounting, and
by existing IFRSs to reduce complexity and
                                                      the IASB issued a discussion paper on reducing
improve consistency in their application (similar
                                                      complexity in reporting financial instruments.
to FAS 157). The IASB intends to issue an
                                                      Additionally, the FASB and the IASB have a joint
exposure draft of its fair value measurement
                                                      project to address the accounting for financial
guidance in Q2 of 2009.
                                                      instruments with characteristics of equity, with a
In September 2008, FASB issued a proposed             goal of issuing a converged standard by 2011.
amendment to FAS 140. The proposed
                                                      The IASB has a project on its agenda to
statement would remove (1) the concept of
                                                      develop a new standard on derecognition that
a qualifying SPE from FAS 140, and (2) the
                                                      is more consistent with the IASB conceptual
exceptions from applying FASB Interpretation
                                                      framework of financial reporting. Ultimately,
No. 46 (revised December 2003) Consolidation
                                                      the two Boards will seek to issue a converged
of Variable Interest Entities to qualifying SPEs.
                                                      derecognition standard.




                                    US GAAP vs. IFRS The basics                                      23
Foreign currency matters


Similarities                                           income. Once a subsidiary’s financial statements
                                                       are remeasured into its functional currency, both
FAS 52 Foreign Currency Translation and IAS
                                                       standards require translation into its parent’s
21 The Effects of Changes in Foreign Exchange
                                                       functional currency with assets and liabilities
Rates are quite similar in their approach
                                                       being translated at the period-end rate, and
to foreign currency translation. While the
                                                       income statement amounts generally at the
guidance provided by each for evaluating the
                                                       average rate, with the exchange differences
functional currency of an entity is different,
                                                       reported in equity. Both standards also permit
it generally results in the same determination
                                                       the hedging of that net investment with exchange
(that is, the currency of the entity’s primary
                                                       differences from the hedging instrument
economic environment). Both GAAPs
                                                       offsetting the translation amounts reported
generally consider the same economies to be
                                                       in equity. The cumulative translation amounts
hyperinflationary, although the accounting for
                                                       reported in equity are reflected in income
an entity operating in such an environment can
                                                       when there is a sale, or complete liquidation
be very different.
                                                       or abandonment of the foreign operation, but
Both GAAPs require foreign currency                    there are differences between the two standards
transactions of an entity to be remeasured into        when the investment in the foreign operation is
its functional currency with amounts resulting         reduced through dividends or repayment of long-
from changes in exchange rates being reported in       term advances as indicated below.

Significant differences
                           US GAAP                                  IFRS
Translation/functional     Local functional currency financial      Local functional currency financial
currency of foreign        statements are remeasured as if the      statements (current and prior period)
operations in a            functional currency was the reporting    are indexed using a general price index,
hyperinflationary          currency (US dollar in the case of a     and then translated to the reporting
economy                    US parent) with resulting exchange       currency at the current rate.
                           differences recognized in income.
Treatment of translation   Translation difference in equity is      A return of investment (for example,
difference in equity       recognized in income only upon           dividend) is treated as a partial disposal
when a partial return of   sale (full or partial), or complete      of the foreign investment and a
a foreign investment is    liquidation or abandonment of the        proportionate share of the translation
made to the parent         foreign subsidiary. No recognition is    difference is recognized in income.
                           made when there is a partial return of
                           investment to the parent.




24                                  US GAAP vs. IFRS The basics
US GAAP                                    IFRS
Consolidation of foreign   The “step-by-step” method is used          The method of consolidation is not
operations                 whereby each entity is consolidated        specified and, as a result, either the
                           into its immediate parent until the        ”direct” or the “step-by-step” method
                           ultimate parent has consolidated the       is used. Under the “direct” method,
                           financial statements of all the entities   each entity within the consolidated
                           below it.                                  group is directly consolidated into
                                                                      the ultimate parent without regard
                                                                      to any intermediate parent. The
                                                                      choice of method could affect the
                                                                      cumulative translation adjustments
                                                                      deferred within equity at intermediate
                                                                      levels, and therefore the recycling of
                                                                      such exchange rate differences upon
                                                                      disposal of an intermediate foreign
                                                                      operation.


Convergence
No convergence activities are underway or
planned for foreign currency matters.




                                     US GAAP vs. IFRS The basics                                               25
Leases


Similarities                                         Under both GAAPs, a lessee would record a
                                                     capital (finance) lease by recognizing an asset
The overall accounting for leases under              and a liability, measured at the lower of the
US GAAP and IFRS (FAS 13 Accounting for              present value of the minimum lease payments
Leases and IAS 17 Leases, respectively) is           or fair value of the asset. A lessee would record
similar, although US GAAP has more specific          an operating lease by recognizing expense
application guidance than IFRS. Both focus           on a straight-line basis over the lease term.
on classifying leases as either capital (IAS 17      Any incentives under an operating lease are
uses the term “finance”) or operating, and           amortized on a straight line basis over the term
both separately discuss lessee and lessor            of the lease.
accounting.
                                                     Lessor accounting
Lessee accounting                                    (excluding real estate)
(excluding real estate)
                                                     Lessor accounting under FAS 13 and IAS 17 is
Both standards require the party that bears          similar and uses the above tests to determine
substantially all the risks and rewards of           whether a lease is a sales-type/direct financing
ownership of the leased property to recognize        lease or an operating lease. FAS 13 specifies
a lease asset and corresponding obligation, and      two additional criteria (that is, collection of
specify criteria (FAS 13) or indicators (IAS 17)     lease payments is reasonably expected and no
to make this determination (that is, whether         important uncertainties surround the amount
a lease is capital or operating). The criteria       of unreimbursable costs to be incurred by the
or indicators of a capital lease are similar in      lessor) for a lessor to qualify for sales-type/
that both standards include the transfer of          direct financing lease accounting that IAS 17
ownership to the lessee at the end of the lease      does not have. Although not specified in IAS
term and a purchase option that, at inception,       17, it is reasonable to expect that if these
is reasonably expected to be exercised. Further,     conditions exist, the same conclusion may be
FAS 13 requires capital lease treatment if the       reached under both standards. If a lease is a
lease term is equal to or greater than 75%           sales-type/direct financing lease, the leased
of the asset’s economic life, while IAS 17           asset is replaced with a lease receivable. If a
requires such treatment when the lease term          lease is classified as operating, rental income
is a “major part” of the asset’s economic life.      is recognized on a straight-line basis over the
FAS 13 specifies capital lease treatment if the      lease term and the leased asset is depreciated
present value of the minimum lease payments          by the lessor over its useful life.
exceeds 90% of the asset’s fair value, while IAS
17 uses the term “substantially all” of the fair
value. In practice, while FAS 13 specifies bright
lines in certain instances (for example, 75% of
economic life), IAS 17’s general principles are
interpreted similarly to the bright line tests. As
a result, lease classification is often the same
under FAS 13 and IAS 17.


26                                 US GAAP vs. IFRS The basics
Significant differences
                           US GAAP                                         IFRS
Lease of land and          A lease for land and buildings that             The land and building elements of
building                   transfers ownership to the lessee or            the lease are considered separately
                           contains a bargain purchase option              when evaluating all indicators unless
                           would be classified as a capital lease          the amount that would initially be
                           by the lessee, regardless of the relative       recognized for the land element is
                           value of the land.                              immaterial, in which case they would
                                                                           be treated as a single unit for purposes
                           If the fair value of the land at inception
                                                                           of lease classification. There is no 25%
                           represents 25% or more of the total
                                                                           test to determine whether to consider
                           fair value of the lease, the lessee
                                                                           the land and building separately when
                           must consider the land and building
                                                                           evaluating certain indicators.
                           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           If the seller does not relinquish more     Gain or loss is recognized immediately,
gain or loss on a sale     than a minor part of the right to use the subject to adjustment if the sales price
and leaseback when         asset, gain or loss is generally deferred  differs from fair value.
the leaseback is an        and amortized over the lease term.
operating leaseback        If 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 seller’s
                           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 where the seller does not             over the lease term.
when the leaseback is a    relinquish more than a minor part of
capital leaseback          the right to use the asset.




                                      US GAAP vs. IFRS The basics                                                 27
Other differences include: (i) the treatment          Convergence
of a leveraged lease by a lessor under FAS 13
                                                      The Boards are jointly working on a long-term
(IAS 17 does not have such classification),
                                                      convergence project on lease accounting
(ii) real estate sale-leasebacks, (iii) real estate
                                                      with an overall objective of comprehensively
sales-type leases, and (iv) the rate used to
                                                      reconsidering the existing guidance issued
discount minimum lease payments to the
                                                      by both standard setters. The Boards have
present value for purposes of determining lease
                                                      tentatively decided to defer the development of
classification and subsequent recognition of a
                                                      a new accounting model for lessors and to adopt
capital lease, including in the event of a renewal.
                                                      an approach that would apply the existing capital
                                                      lease model, adapted as necessary, to all leases.
                                                      A joint discussion paper is planned to be issued
                                                      in the first quarter of 2009, with the Boards then
                                                      moving towards publication of an exposure draft.




28                                  US GAAP vs. IFRS The basics
Income taxes


Similarities                                          Significant differences and
FAS 109 Accounting for Income Taxes and               convergence
IAS 12 Income Taxes provide the guidance              The IASB is expected to publish an exposure
for income tax accounting under US GAAP               draft to replace IAS 12 in 2009 that will eliminate
and IFRS, respectively. Both pronouncements           certain of the differences that currently exist
require entities to account for both current tax      between US GAAP and IFRS. The table below
effects and expected future tax consequences          highlights the significant differences in the
of events that have been recognized (that is,         current literature, as well as the expected
deferred taxes) using an asset and liability          proposed accounting under the IASB’s
approach. Further, deferred taxes for temporary       exposure draft. While initially participating in
differences arising from non-deductible goodwill      the deliberations on this proposed standard,
are not recorded under either approach, and           the FASB decided to suspend deliberations on
tax effects of items accounted for directly in        this project until the IASB issues its exposure
equity during the current year also are allocated     document on the proposed replacement to
directly to equity. Finally, neither GAAP permits     IAS 12 for public comment. The FASB is expected
the discounting of deferred taxes.                    to solicit input from US constituents regarding
                                                      the IASB’s proposed replacement to IAS 12 and
                                                      then determine whether to undertake a project to
                                                      fully eliminate the differences in the accounting
                                                      for income taxes by adopting the revised IAS 12.

                         US GAAP                      IFRS                         IASB exposure draft
Tax basis                Tax basis is a question of   Tax basis is generally the   IFRS is expected to
                         fact under the tax law.      amount deductible or         propose a new definition
                         For most assets and          taxable for tax purposes.    for tax basis that will
                         liabilities there is no      The manner in which          eliminate consideration
                         dispute on this amount;      management intends           of management’s intent
                         however, when uncertainty    to settle or recover the     in determination of the
                         exists it is determined in   carrying amount affects      tax basis.
                         accordance with FIN 48       the determination of tax
                         Accounting for Uncertainty   basis.
                         in Income Taxes.




                                  US GAAP vs. IFRS The basics                                             29
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences
US GAAP vs IFRS: The key differences

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US GAAP vs IFRS: The key differences

  • 1. US GAAP vs. IFRS The basics January 2009
  • 2.
  • 3. Table of contents 2 Introduction 5 Financial statement presentation 7 Interim financial reporting 8 Consolidations, joint venture accounting and equity method investees 11 Business combinations 13 Inventory 14 Long-lived assets 16 Intangible assets 18 Impairment of long-lived assets, goodwill and intangible assets 20 Financial instruments 24 Foreign currency matters 26 Leases 29 Income taxes 32 Provisions and contingencies 34 Revenue recognition 36 Share-based payments 38 Employee benefits other than share-based payments 40 Earnings per share 41 Segment reporting 42 Subsequent events 43 Related parties 44 Appendix — The evolution of IFRS
  • 4. Introduction It is not surprising that many people who follow No publication that compares two broad sets of the development of worldwide accounting accounting standards can include all differences standards today might be confused. Convergence that could arise in accounting for the myriad of is a high priority on the agendas of both the business transactions that could possibly occur. US Financial Accounting Standards Board (FASB) The existence of any differences — and their and the International Accounting Standards materiality to an entity’s financial statements — Board (IASB) — and “convergence” is a term depends on a variety of specific factors including: that suggests an elimination or coming the nature of the entity, the detailed transactions together of differences. Yet much is still made it enters into, its interpretation of the more of the many differences that exist between general IFRS principles, its industry practices, US GAAP as promulgated by the FASB and and its accounting policy elections where International Financial Reporting Standards US GAAP and IFRS offer a choice. This guide (IFRS) as promulgated by the IASB, suggesting focuses on those differences most commonly that the two GAAPs continue to speak found in present practice and, where applicable, languages that are worlds apart. This apparent provides an overview of how and when those contradiction has prompted many to ask just differences are expected to converge. how different are the two sets of standards? And where differences exist, why do they exist, and when, if ever, will they be eliminated? Why do differences exist? As the international standards were developed, In this guide, “US GAAP v. IFRS: The basics,” the IASB and its predecessor, the International we take a top level look into these questions Accounting Standards Committee (IASC), and provide an overview, by accounting area, had the advantage of being able to draw on both of where the standards are similar and the latest thinking of standard setters from also where they diverge. While the US and around the world. As a result, the international international standards do contain differences, standards contain elements of accounting the general principles, conceptual framework, standards from a variety of countries. And and accounting results between them are often even where an international standard looked the same or similar, even though the areas of to an existing US standard as a starting point, divergence seem to have disproportionately the IASB was able to take a fresh approach overshadowed these similarities. We believe to that standard. In doing so, the IASB could that any discussion of this topic should not lose avoid some of the perceived problems in the sight of the fact that the two sets of standards FASB standard — for example, exceptions are generally more alike than different for most to the standard’s underlying principles commonly encountered transactions, with IFRS that had resulted from external pressure being largely, but not entirely, grounded in the during the exposure process, or practice same basic principles as US GAAP. difficulties that had emerged subsequent 2 US GAAP vs. IFRS The basics
  • 5. to the standard’s issuance — and attempt to Will the differences ever be improve them. Further, as part of its annual eliminated? “Improvements Project,” the IASB reviews its Both the FASB and IASB (the Boards) publicly existing standards to enhance their clarity and declared their commitment to the convergence consistency, again taking advantage of more of IFRS and US GAAP in the “Norwalk current thinking and practice. Agreement” in 2002, and since that time have For these reasons, some of the differences made significant strides toward that goal, between US GAAP and IFRS are embodied in including formally updating their agreement in the standards themselves — that is, they are 2008. Additionally, the United States Securities intentional deviations from US requirements. and Exchange Commission (SEC) has been very active in this area. For example, within the past Still other differences have emerged two years, the SEC eliminated the requirement through interpretation. As a general rule, for foreign private issuers to reconcile their IFRS standards are more broad than their IFRS results to US GAAP and proposed an US counterparts, with limited interpretive updated “Roadmap” addressing the future use guidance. The IASB has generally avoided of IFRS in the United States. The Roadmap issuing interpretations of its own standards, includes the potential for voluntary adoption preferring to instead leave implementation of IFRS by certain large companies as early as of the principles embodied in its standards 2009 and contemplates mandatory adoption to preparers and auditors, and its official for all companies by 2014, 2015 or 2016. The interpretive body, the International Financial SEC has stated that continued progress towards Reporting Interpretations Committee (IFRIC). convergence is an important milestone that it While US standards contain underlying will assess when ultimately deciding on the use principles as well, the strong regulatory and of IFRS in the United States. legal environment in the US market has resulted in a more prescriptive approach — with far more Convergence efforts alone will not totally “bright lines,” comprehensive implementation eliminate all differences between US GAAP guidance and industry interpretations. and IFRS. In fact, differences continue to exist in standards for which convergence efforts Therefore, while some might read the broader already have been completed, and for which IFRS standard to require an approach similar no additional convergence work is planned. to that contained in its more detailed US And for those standards currently on the counterpart, others might not. Differences also Boards’ convergence agenda, unless the result from this divergence in interpretation. words of the standards are totally conformed, interpretational differences will almost certainly continue to arise. US GAAP vs. IFRS The basics 3
  • 6. The success of a uniform set of global accounting standards also will depend on the willingness of national regulators and industry groups to cooperate and to avoid issuing local interpretations of IFRS and guidance that provides exceptions to IFRS principles. Some examples of this have already begun to emerge and could threaten the achievement of international harmonization. In planning a possible move to IFRS, it is important that US companies monitor progress on the Boards’ convergence agenda to avoid spending time now analyzing differences that most likely will be eliminated in the near future. At present, it is not possible to know the exact extent of convergence that will exist at the time US public companies may be required to adopt the international standards. However, that should not stop preparers, users and auditors from gaining a general understanding of the similarities and key differences between IFRS and US GAAP, as well as the areas presently expected to converge. We hope you find this guide a useful tool for that purpose. January 2009 4 US GAAP vs. IFRS The basics
  • 7. Financial statement presentation Similarities financial statements. Further, both frameworks require that the financial statements be There are many similarities between US GAAP prepared on the accrual basis of accounting and IFRS relating to financial statement (with the exception of the cash flows statement) presentation. For example, under both except for rare circumstances. Both GAAPs frameworks, the components of a complete set have similar concepts regarding materiality and of financial statements include: balance sheet, consistency that entities have to consider in income statement, other comprehensive income preparing their financial statements. Differences for US GAAP or statement of recognized income between the two tend to arise in the level of and expense (SORIE) for IFRS, statement of specific guidance. cash flows, and accompanying notes to the Significant differences US GAAP IFRS Financial periods Generally, comparative financial Comparative information must be required statements are presented; however, a disclosed in respect of the previous single year may be presented in certain period for all amounts reported in the circumstances. Public companies must 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 IAS 1 Presentation of Financial and income statement US GAAP to prepare the balance sheet Statements does not prescribe a and income statement in accordance standard layout, but includes a list with a specific layout; however, public of minimum items. These minimum companies must follow the detailed items are less prescriptive than the requirements in Regulation S-X. requirements in Regulation S-X. Presentation of debt Debt for which there has been a Debt associated with a covenant as current versus non- covenant violation may be presented violation must be presented as current current in the balance as non-current if a lender agreement to unless the lender agreement was sheet waive the right to demand repayment reached prior to the balance sheet date. for more than one year exists prior to Deferred taxes are presented as non- the issuance of the financial statements. current. (Note: In the joint convergence Deferred taxes are presented as project on income taxes, IFRS is current or non-current based on the expected to converge with US GAAP.) nature of the related asset or liability. Income statement — SEC registrants are required to present Entities may present expenses based on classification of expenses based on function (for either function or nature (for example, expenses example, cost of sales, administrative). salaries, depreciation). However, if function is selected, certain disclosures about the nature of expenses must be included in the notes. US GAAP vs. IFRS The basics 5
  • 8. US GAAP IFRS Income statement — Restricted to items that are both Prohibited. extraordinary items unusual and infrequent. Income statement — Discontinued operations classification Discontinued operations classification discontinued operations is for components held for sale or to is for components held for sale or to be presentation be disposed of, provided that there disposed of that are either a separate will not be significant continuing cash major line of business or geographical flows or involvement with the disposed area or a subsidiary acquired component. exclusively with an intention to resale. Changes in equity Present all changes in each caption of At a minimum, present components stockholders’ equity in either a footnote related to “recognized income and or a separate statement. expense” as part of a separate statement (referred to as the SORIE if it contains no other components). Other changes in equity either disclosed in the notes, or presented as part of a single, combined statement of all changes in equity (in lieu of the SORIE). Disclosure of SEC regulations define certain key Certain traditional concepts such as performance measures measures and require the presentation “operating profit” are not defined; of certain headings and subtotals. therefore, diversity in practice exists Additionally, public companies are regarding line items, headings and prohibited from disclosing non-GAAP subtotals presented on the income measures in the financial statements statement when such presentation is and accompanying notes. relevant to an understanding of the entity’s financial performance. Convergence face of the financial statements, and may ultimately result in significant changes in the In April 2004, the FASB and the IASB (the current presentation format of the financial Boards) agreed to undertake a joint project statements under both GAAPs. on financial statement presentation. As part of “Phase A” of the project, the IASB issued In September 2008, the Boards issued a revised IAS 1 in September 2007 (with an proposed amendments to FAS 144 and IFRS 5 effective date for annual reporting periods to converge the definition of discontinued ending after January 1, 2009) modifying operations. Under the proposals, a discontinued the requirements of the SORIE within IAS 1 operation would be a component of an entity and bringing it largely in line with the FASB’s that is either (1) an operating segment (as statement of other comprehensive income. As defined in FAS 131 and IFRS 8, respectively) part of “Phase B,” the Boards each issued an held for sale or that has been disposed of, or initial discussion document in October 2008, (2) a business (as defined in FAS 141(R)) that with comments due by April 2009. This phase meets the criteria to be classified as held for of the project addresses the more fundamental sale on acquisition. issues for presentation of information on the 6 US GAAP vs. IFRS The basics
  • 9. Interim financial reporting Similarities financial statements (which are similar but not identical) and provide for comparable disclosure APB 28 and IAS 34 (both entitled Interim requirements. Neither standard mandates Financial Reporting) are substantially similar which entities are required to present interim with the exception of the treatment of certain financial information, that being the purview costs as described below. Both require an of local securities regulators. For example, entity to use the same accounting policies US public companies must follow the SEC’s that were in effect in the prior year, subject Regulation S-X for the purpose of preparing to adoption of new policies that are disclosed. interim financial information. Both standards allow for condensed interim Significant difference 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 discrete reporting period. A cost that a result, certain costs that benefit does not meet the definition of an asset more than one interim period may at the end of an interim period is not be allocated among those periods, deferred and a liability recognized at an resulting in deferral or accrual of interim reporting date must represent certain costs. For example, certain an existing obligation. For example, inventory cost variances may be inventory cost variances that do not deferred on the basis that the interim meet the definition of an asset cannot statements are an integral part of an be deferred. However, income taxes annual period. are accounted for based on an annual effective tax rate (similar to US GAAP). Convergence As part of their joint Financial Statement Presentation project, the FASB will address presentation and display of interim financial information in US GAAP, and the IASB may reconsider the requirements of IAS 34. This phase of the Financial Statement Presentation project has not commenced. US GAAP vs. IFRS The basics 7
  • 10. Consolidations, joint venture accounting and equity method investees Similarities for all of the entities within a consolidated group, with certain exceptions under US GAAP The principle guidance for consolidation (for example, a subsidiary within a specialized of financial statements under US GAAP is industry may retain the specialized accounting ARB 51 Consolidated Financial Statements policies in consolidation). Under both GAAPs, (as amended by FAS 160 Noncontrolling the consolidated financial statements of the Interests in Consolidated Financial Statements) parent and its subsidiaries may be based and FAS 94 Consolidation of All Majority- on different reporting dates as long as the Owned Subsidiaries; while IAS 27 (Amended) difference is not greater than three months. Consolidated and Separate Financial However, under IFRS a subsidiary’s financial Statements provides the guidance under statements should be as of the same date as IFRS. Special purpose entities are addressed the financial statements of the parent’s unless in FIN 46 (Revised) Consolidation of Variable is it impracticable to do so. Interest Entities and SIC 12 Consolidation — Special Purpose Entities in US GAAP and IFRS An equity investment that gives an investor respectively. Under both US GAAP and IFRS, significant influence over an investee (referred the determination of whether or not entities to as “an associate” in IFRS) is considered an are consolidated by a reporting enterprise is equity-method investment under both US GAAP based on control, although differences exist (APB 18 The Equity Method of Accounting for in the definition of control. Generally, under Investments in Common Stock) and IFRS (IAS 28 both GAAPs all entities subject to the control of Investments in Associates), if the investee is the reporting enterprise must be consolidated not consolidated. Further, the equity method of (note that there are limited exceptions in accounting for such investments, if applicable, US GAAP in certain specialized industries). generally is consistent under both GAAPs. Further, uniform accounting policies are used Significant differences US GAAP IFRS Consolidation model Focus is on controlling financial Focus is on the concept of the power interests. All entities are first evaluated to control, with control being the as potential variable interest entities parent’s ability to govern the financial (VIEs). If a VIE, FIN 46 (Revised) and operating policies of an entity to guidance is followed (below). Entities obtain benefits. Control presumed to controlled by voting rights are exist if parent owns greater than 50% consolidated as subsidiaries, but of the votes, and potential voting rights potential voting rights are not included must be considered. Notion of “de facto in this consideration. The concept of control” must also be considered. “effective control” exists, but is rarely employed in practice. 8 US GAAP vs. IFRS The basics
  • 11. US GAAP IFRS Special purpose entities FIN 46 (Revised) requires the primary Under SIC 12, SPEs (entities created to (SPE) beneficiary (determined based on the accomplish a narrow and well-defined consideration of economic risks and objective) are consolidated when the rewards) to consolidate the VIE. substance of the relationship indicates that an entity controls the SPE. Preparation of Required, although certain industry- Generally required, but there is a limited consolidated financial specific exceptions exist (for example, exemption from preparing consolidated statements — general investment companies). financial statements for a parent company that is itself a wholly-owned subsidiary, or is a partially-owned subsidiary if certain conditions are met. Preparation of The effects of significant events The effects of significant events consolidated financial occurring between the reporting dates occurring between the reporting dates statements — different when different dates are used are when different dates are used are reporting dates of parent disclosed in the financial statements. adjusted for in the financial statements. and subsidiary(ies) Presentation of Presented outside of equity on the Presented as a separate component in noncontrolling or balance sheet (prior to the adoption of equity on the balance sheet. “minority” interest FAS 160). Equity-method FAS 159 The Fair Value Option for IAS 28 requires investors (other than investments Financial Assets and Financial Liabilities venture capital organizations, mutual gives entities the option to account funds, unit trusts, and similar entities) for their equity-method investments to use the equity-method of accounting at fair value. For those equity-method for such investments in consolidated investments for which management financial statements. If separate does not elect to use the fair value financial statements are presented option, the equity method of accounting (that is, those presented by a parent or is required. investor), subsidiaries and associates can be accounted for at either cost or Uniform accounting policies between fair value. investor and investee are not required. Uniform accounting policies between investor and investee are required. Joint ventures Generally accounted for using the IAS 31 Investments in Joint Ventures equity-method of accounting, with the permits either the proportionate limited exception of unincorporated consolidation method or the equity entities operating in certain industries method of accounting. which may follow proportionate consolidation. US GAAP vs. IFRS The basics 9
  • 12. Convergence At the time of this publication, the FASB is proposing amendments to FIN 46 (Revised). As part of their joint project on business Additionally, the IASB is working on a combinations, the FASB issued FAS 160 consolidation project that would replace IAS 27 (effective for fiscal years beginning on or after (amended) and SIC 12 and is expected to provide December 15, 2008) and the IASB amended for a single consolidation model within IFRS. IAS 27 (effective for fiscal years beginning It is currently unclear whether these projects on or after July 1, 2009, with early adoption will result in additional convergence, and future permitted), thereby eliminating substantially all developments should be monitored. of the differences between US GAAP and IFRS pertaining to noncontrolling interests, outside of the initial accounting for the noncontrolling interest in a business combination (see the Business Combinations section). In addition, the IASB recently issued an exposure draft that proposes the elimination of proportionate consolidation for joint ventures. 10 US GAAP vs. IFRS The basics
  • 13. Business combinations Similarities assets, liabilities and noncontrolling interests of the acquired entity are measured (as described The issuance of FAS 141(R) and IFRS 3(R) in the table below, IFRS 3(R) provides an (both entitled Business Combinations), alternative to measuring noncontrolling interest represent the culmination of the first major at fair value), with limited exceptions. Even collaborative convergence project between the though the new standards are substantially IASB and the FASB. Pursuant to FAS 141(R) converged, certain differences will exist once and IFRS 3(R), all business combinations are the new standards become effective. The new accounted for using the acquisition method. standards will be effective for annual periods Under the acquisition method, upon obtaining beginning on or after December 15, 2008, control of another entity, the underlying and July 1, 2009, for companies following transaction should be measured at fair value, US GAAP and IFRS, respectively. and this should be the basis on which the Significant differences US GAAP IFRS Measurement of Noncontrolling interest is measured Noncontrolling interest is measured noncontrolling interest at fair value, which includes the either at fair value including goodwill or noncontrolling interest’s share of its proportionate share of the fair value goodwill. of the acquiree’s identifiable net assets, exclusive of goodwill. Assets and liabilities Initial Recognition Initial Recognition arising from Distinguishes between contractual Contingent liabilities are recognized contingencies and noncontractual contingencies. as of the acquisition date if there is Contractual contingencies are measured a present obligation that arises from at fair value at the acquisition date, past events and its fair value can be while noncontractual contingencies measured reliably. Contingent assets are recognized at fair value at the are not recognized. acquisition date only if it is more likely than not that the contingency meets the definition of an asset or liability. Subsequent Measurement Subsequent Measurement Contingently liabilities are Contingent liabilities are subsequently subsequently measured at the higher measured at the higher of its acquisition- of its acquisition-date fair value, or date fair value less, if appropriate, the amount that would be recognized cumulative amortization recognized in if applying FAS 5, Accounting for accordance with IAS 18, Revenue, or Contingencies. (See “Provisions and the amount that would be recognized if contingencies” for differences between applying IAS 37, Provisions, Contingent FAS 5 and IAS 37.) Liabilities and Contingent Assets.. US GAAP vs. IFRS The basics 11
  • 14. US GAAP IFRS Acquiree operating If the terms of an acquiree operating Separate recognition of an intangible leases lease are favorable or unfavorable asset or liability is required only if the relative to market terms, the acquirer acquiree is a lessee. If the acquiree is recognizes an intangible asset or the lessor, the terms of the lease are liability, respectively, regardless of taken into account in estimating the fair whether the acquiree is the lessor or value of the asset subject to the lease the lessee. – separate recognition of an intangible asset or liability is not required. Combination of entities Accounted for in a manner similar to a Outside the scope of IFRS 3R. In under common control pooling of interests (historical cost). practice, either follow an approach similar to US GAAP or apply the purchase method if there is substance to the transaction. Other differences may arise due to different Convergence accounting requirements of other existing No further convergence is planned at this US GAAP-IFRS literature (for example, identifying time. Note, however, that as of the date of this the acquirer, definition of control, definition of publication, the FASB has issued a proposed fair value, replacement of share-based payment FSP that would change the accounting for awards, initial classification and subsequent preacquisition contingencies under FAS 141(R). measurement of contingent consideration, initial The proposed FSP proposes a model that is recognition and measurement of income taxes, very similar to the existing requirements of and initial recognition and measurement of FAS 141 for purposes of initial recognition. employee benefits). Assets and liabilities measured at fair value would continue to be subject to subsequent measurement guidance similar to that currently described in FAS 141(R). 12 US GAAP vs. IFRS The basics
  • 15. Inventory Similarities for cost measurement, such as standard cost method or retail method, are similar under ARB 43 Chapter 4 Inventory Pricing and IAS both US GAAP and IFRS. Further, under both 2 Inventories are both based on the principle GAAPs the cost of inventory includes all direct that the primary basis of accounting for expenditures to ready inventory for sale, inventory is cost. Both define inventory as including allocable overhead, while selling assets held for sale in the ordinary course of costs are excluded from the cost of inventories, business, in the process of production for such as are most storage costs and general sale, or to be consumed in the production of administrative costs. goods or services. The permitted techniques 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 (best estimate replacement cost as long as market is of the net amounts inventories are not greater than net realizable value expected to realize. This amount may (estimated selling price less reasonable or may not equal fair value). costs of completion and sale) and is not less than net realizable value reduced by a normal sales margin. Reversal of inventory Any write-downs of inventory to the Previously recognized impairment write-downs lower of cost or market create a new losses are reversed, up to the amount cost basis that subsequently cannot be of the original impairment loss when reversed. the reasons for the impairment no longer exist. 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 RIM. Reduction of the carrying cost of (RIM) the carrying cost of inventory to net inventory to below the lower of cost or realizable value, less an allowance for net realizable value is not allowed. an approximately normal profit margin, which may be less than both original cost and net realizable value. Convergence abnormal amounts of idle facility expense, freight, handling costs and spoilage. At present, In November 2004, the FASB issued FAS 151 there are no other ongoing convergence efforts Inventory Costs to address a narrow difference with respect to inventory. between US GAAP and IFRS related to the accounting for inventory costs, in particular, US GAAP vs. IFRS The basics 13
  • 16. Long-lived assets Similarities between US GAAP and IFRS in the specific costs and assets that are included within Although US GAAP does not have a these categories as well as the requirement to comprehensive standard that addresses long- capitalize these costs. lived assets, its definition of property, plant and equipment is similar to IAS 16 Property, Plant and Equipment, which addresses tangible assets Depreciation held for use that are expected to be used for Depreciation of long-lived assets is required more than one reporting period. Other concepts on a systematic basis under both accounting that are similar include the following: models. FAS 154 Accounting Changes and Error Corrections and IAS 8 Accounting Cost Policies, Changes in Accounting Estimates and Error Corrections both treat changes Both accounting models have similar recognition in depreciation method, residual value and criteria, requiring that costs be included in the useful economic life as a change in accounting cost of the asset if future economic benefits estimate requiring prospective treatment. are probable and can be reliably measured. The costs to be capitalized under both models are similar. Neither model allows the capitalization Assets held for sale of start-up costs, general administrative and Assets held for sale are discussed in FAS overhead costs or regular maintenance. 144 and IFRS 5 Non-Current Assets Held for However, both US GAAP and IFRS require that Sale and Discontinued Operations, with both the costs of dismantling an asset and restoring standards having similar held for sale criteria. its site (that is, the costs of asset retirement Under both standards, the asset is measured under FAS 143 Accounting for Asset Retirement at the lower of its carrying amount or fair Obligations or IAS 37 Provisions, Contingent value less costs to sell; the assets are not Liabilities and Contingent Assets) be included depreciated and are presented separately on in the cost of the asset. Both models require the face of the balance sheet. Exchanges of a provision for asset retirement costs to be nonmonetary similar productive assets are also recorded when there is a legal obligation, treated similarly under APB 29 Accounting for although IFRS requires provision in other Nonmonetary Exchanges as amended by FAS circumstances as well. 153 Accounting for Nonmonetary Transactions and IAS 16, both of which allow gain/loss Capitalized interest recognition if the exchange has commercial substance and the fair value of the exchange FAS 34 Capitalization of Interest and IAS 23 can be reliably measured. Borrowing Costs address the capitalization of borrowing costs (for example, interest costs) directly attributable to the acquisition, construction or production of a qualifying asset. Qualifying assets are generally defined similarly under both accounting models. However, there are significant differences 14 US GAAP vs. IFRS The basics
  • 17. Significant differences US GAAP IFRS Revaluation of assets Revaluation not permitted. Revaluation is a permitted accounting policy election for an entire class of assets, requiring revaluation to fair value on a regular basis. Depreciation of asset Component depreciation permitted but Component depreciation required if components not common. components of an asset have differing patterns of benefit. 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. Borrowing costs funds generally cannot offset interest are offset by investment income earned costs incurred during the period. on those borrowings. For borrowings associated with a For borrowings associated with a specific qualifying asset, borrowing specific qualifying asset, actual costs equal to the weighted average borrowing costs are capitalized. accumulated expenditures times the borrowing rate are capitalized. Costs of a major Multiple accounting models have Costs that represent a replacement overhaul evolved in practice, including: expense of a previously identified component costs as incurred, capitalize costs and of an asset are capitalized if future amortize through the date of the next economic benefits are probable and overhaul, or follow the IFRS approach. the costs can be reliably measured. Investment property Investment property is not separately Investment property is separately defined and, therefore, is accounted for defined in IAS 40 as an asset held to as held for use or held for sale. earn rent or for capital appreciation (or both) and may include property held by lessees under a finance/ operating lease. Investment property may be accounted for on a historical cost basis or on a fair value basis as an accounting policy election. Capitalized operating lease classified as investment property must be accounted for using the fair value model. Other differences include: (i) hedging gains Convergence and losses related to the purchase of assets, No further convergence is planned at this time. (ii) constructive obligations to retire assets, (iii) the discount rate used to calculate asset retirement costs, and (iv) the accounting for changes in the residual value. US GAAP vs. IFRS The basics 15
  • 18. Intangible assets Similarities internally developed intangibles are not recognized as an asset under either FAS 142 The definition of intangible assets as non- or IAS 38. Moreover, internal costs related monetary assets without physical substance is to the research phase of research and the same under both US GAAP’s FAS 141(R) development are expensed as incurred under and FAS 142 Goodwill and Other Intangible both accounting models. Assets and the IASB’s IFRS 3(R) and IAS 38 Intangible Assets. The recognition criteria Amortization of intangible assets over their for both accounting models require that estimated useful lives is required under both there be probable future economic benefits US GAAP and IFRS, with one minor exception in and costs that can be reliably measured. FAS 86 Accounting for the Costs of Computer However, some costs are never capitalized Software to be Sold, Leased or Otherwise as intangible assets under both models, such Marketed related to the amortization of as start-up costs. Goodwill is recognized only computer software assets. In both, if there is in a business combination in accordance no foreseeable limit to the period over which with FAS 141(R) and IFRS 3(R). In general, an intangible asset is expected to generate intangible assets that are acquired outside net cash inflows to the entity, the useful life is of a business combination are recognized at considered to be indefinite and the asset is not fair value. With the exception of development amortized. Goodwill is never amortized. costs (addressed in the following table), Significant differences US GAAP IFRS Development costs Development costs are expensed as Development costs are capitalized incurred unless addressed by a separate when technical and economic feasibility standard. Development costs related of a project can be demonstrated to computer software developed for in accordance with specific criteria. external use are capitalized once Some of the stated criteria include: technological feasibility is established in demonstrating technical feasibility, accordance with specific criteria (FAS intent to complete the asset, and ability 86). In the case of software developed to sell the asset in the future, as well as for internal use, only those costs incurred others. Although application of these during the application development stage principals may be largely consistent (as defined in SOP 98-1 Accounting with FAS 86 and SOP 98-1, there for the Costs of Computer Software is no separate guidance addressing Developed or Obtained for Internal Use) computer software development costs. may be capitalized. Advertising costs Advertising and promotional costs are Advertising and promotional costs are either expensed as incurred or expensed expensed as incurred. A prepayment when the advertising takes place for the may be recognized as an asset only first time (policy choice). Direct response when payment for the goods or advertising may be capitalized if the services is made in advance of the specific criteria in SOP 93-07 Reporting entity’s having access to the goods or on Advertising Costs are met. receiving the services. 16 US GAAP vs. IFRS The basics
  • 19. US GAAP IFRS Revaluation Revaluation is not permitted Revaluation to fair value of intangible assets other than goodwill is a permitted accounting policy election for a class of intangible assets. Because revaluation requires reference to an active market for the specific type of intangible, this is relatively uncommon in practice. Convergence the 2008 MOU, the FASB indicated that it will consider in the future whether to undertake a While the convergence of standards on intangible project to eliminate differences in the accounting assets was part of the 2006 “Memorandum of for research and development costs by fully Understanding” (MOU) between the FASB and adopting IAS 38 at some point in the future. the IASB, both boards agreed in 2007 not to add this project to their agenda. However, in US GAAP vs. IFRS The basics 17
  • 20. Impairment of long-lived assets, goodwill and intangible assets Similarities that an asset found to be impaired be written down and an impairment loss recognized. FAS Both US GAAP and IFRS contain similarly 142, FAS 144 Accounting for the Impairment defined impairment indicators for assessing the or Disposal of Long-Lived Assets, and IAS 36 impairment of long-lived assets. Both standards Impairment of Assets apply to most long-lived require goodwill and intangible assets with and intangible assets, although some of the indefinite lives to be reviewed at least annually scope exceptions listed in the standards differ. for impairment and more frequently if Despite the similarity in overall objectives, impairment indicators are present. Long-lived differences exist in the way in which impairment assets are not tested annually, but rather is reviewed, recognized and measured. when there are indicators of impairment. The impairment indicators in US GAAP and IFRS are similar. Additionally, both GAAPs require Significant differences US GAAP IFRS Method of determining Two-step approach requires a One-step approach requires that impairment — long-lived recoverability test be performed impairment testing be performed if assets first (carrying amount of the asset impairment indicators exist. is compared to the sum of future undiscounted cash flows generated through use and eventual disposition). If it is determined that the asset is not recoverable, impairment testing must be performed. 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 FAS 157. 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). (Note that the definition of fair value in IFRS has certain differences from the definition in FAS 157.) Allocation of goodwill Goodwill is allocated to a reporting Goodwill is allocated to a cash- unit, which is an operating segment or generating unit (CGU) or group of one level below an operating segment CGUs which represents the lowest level (component). within the entity at which the goodwill is monitored for internal management purposes and cannot be larger than an operating segment as defined in IFRS 8, Operating Segments. 18 US GAAP vs. IFRS The basics
  • 21. US GAAP IFRS Method of determining Two-step approach requires a One-step approach requires that impairment — goodwill recoverability test to be performed an impairment test be done at the first at the reporting unit level (carrying cash generating unit (CGU) level by amount of the reporting unit is comparing the CGU’s carrying amount, compared to the reporting unit fair including goodwill, with its recoverable value). If the carrying amount of the amount. 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 CGU’s 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 The amount by which the carrying calculation — indefinite value of the asset exceeds its fair value. value of the asset exceeds its life intangible assets recoverable amount. Reversal of loss Prohibited for all assets to be held and Prohibited for goodwill. Other long- used. lived assets must be reviewed annually for reversal indicators. If appropriate, loss may be reversed up to the newly estimated recoverable amount, not to exceed the initial carrying amount adjusted for depreciation. Convergence Impairment is one of the short-term convergence projects agreed to by the FASB and IASB in their 2006 MOU. However, as part of their 2008 MOU, the boards agreed to defer work on completing this project until their other convergence projects are complete. US GAAP vs. IFRS The basics 19
  • 22. Financial instruments Similarities and Financial Liabilities. IFRS guidance for financial instruments, on the other hand, is The US GAAP guidance for financial limited to three standards (IAS 32 Financial instruments is contained in several standards. Instruments: Presentation, IAS 39 Financial Those standards include, among others, FAS Instruments: Recognition and Measurement, 65 Accounting for Certain Mortgage Banking and IFRS 7 Financial Instruments: Disclosures). Activities, FAS 107 Disclosures about Fair Value Both GAAPs require financial instruments to be of Financial Instruments, FAS 114 Accounting classified into specific categories to determine by Creditors for Impairment of a Loan, FAS115 the measurement of those instruments, Accounting for Certain Investments in Debt clarify when financial instruments should and Equity Securities, FAS 133 Accounting for be recognized or derecognized in financial Derivative Instruments and Hedging Activities, statements, and require the recognition of FAS 140 Accounting for Transfers and Servicing all derivatives on the balance sheet. Hedge of Financial Assets and Extinguishments of accounting and use of a fair value option is Liabilities, FAS 150 Accounting for Certain permitted under both. Each GAAP also requires Financial Instruments with Characteristics of detailed disclosures in the notes to financial both Liabilities and Equity, FAS 155 Accounting statements for the financial instruments for Certain Hybrid Financial Instruments, reported in the balance sheet. FAS 157 Fair Value Measurements, and FAS 159 The Fair Value Option for Financial Assets Significant differences US GAAP IFRS Fair value measurement One measurement model whenever Various IFRS standards use slightly fair value is used (with limited varying wording to define fair value. exceptions). Fair value is the price Generally fair value represents that would be received to sell an asset the amount that an asset could be or paid to transfer a liability in an exchanged for, or a liability settled orderly transaction between market between knowledgeable, willing parties participants at the measurement date. in an arm’s length transaction. Fair value is an exit price, which may differ from the transaction (entry) At inception, transaction (entry) price price. generally is considered fair value. Use of fair value option Financial instruments can be measured Financial instruments can be measured at fair value with changes in fair value at fair value with changes in fair value reported through net income, except reported through net income provided for specific ineligible financial assets that certain criteria, which are more and liabilities. restrictive than under US GAAP, are met. 20 US GAAP vs. IFRS The basics
  • 23. US GAAP IFRS Day one gains and losses Entities are not precluded from Day one gains and losses are recognizing day one gains and losses recognized only when all inputs to the on financial instruments reported at measurement model are observable. fair value even when all inputs to the measurement model are not observable. For example, a day one gain or loss may occur when the transaction occurs in a market that differs from the reporting entity’s exit market. Debt vs. equity US GAAP specifically identifies certain Classification of certain instruments with classification instruments with characteristics of characteristics of both debt and equity both debt and equity that must be focuses on the contractual obligation to classified as liabilities. deliver cash, assets or an entity’s own shares. Economic compulsion does not constitute a contractual obligation. Certain other contracts that are indexed Contracts that are indexed to, and to, and potentially settled in, a company’s potentially settled in, a company’s own own stock may be classified as equity stock are classified as equity when if they: (1) require physical settlement settled by delivering a fixed number of or net-share settlement, or (2) give the shares for a fixed amount of cash. issuer a choice of net-cash settlement or settlement in its own shares. Compound (hybrid) Compound (hybrid) financial instruments Compound (hybrid) financial financial instruments (for example, convertible bonds) are not instruments are required to be split split into debt and equity components into a debt and equity component and, unless certain specific conditions are if applicable, a derivative component. met, but they may be bifurcated into The derivative component may be debt and derivative components, with subjected to fair value accounting. the derivative component subjected to fair value accounting. Impairment recognition — Declines in fair value below cost may Generally, only evidence of credit Available for Sale (AFS) result in an impairment loss being default results in an impairment being financial instruments recognized in the income statement recognized in the income statement of on an AFS debt security due solely to an AFS debt instrument. a change in interest rates (risk-free or Impairment losses recognized through otherwise) if the entity does not have the income statement for available- the positive ability and intent to hold for-sale equity securities cannot be the asset for a period of time sufficient reversed through the income statement to allow for any anticipated recovery in for future recoveries. However, fair value. impairment losses for debt instruments When an impairment is recognized classified as available-for-sale may be through the income statement, a reversed through the income statement new cost basis in the investment is if the fair value of the asset increases in established. Such losses can not be a subsequent period and the increase reversed for any future recoveries. can be objectively related to an event occurring after the impairment loss was recognized. US GAAP vs. IFRS The basics 21
  • 24. US GAAP IFRS Hedge effectiveness — Permitted. Not permitted. shortcut method for interest rate swaps Hedging a component The risk components that may be Allows entities to hedge components of a risk in a financial hedged are specifically defined by the (portions) of risk that give rise to instrument literature, with no additional flexibility. changes in fair value. 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, depending liabilities, except for certain reclassified 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. Derecognition of Derecognition of financial assets (sales Derecognition is based on a mixed financial assets treatment) occurs when effective model that considers both transfer of control has been surrendered over risks and rewards and control. If the the financial assets. Control has been transferor has neither retained nor surrendered only if certain specific transferred substantially all of the criteria have been met, including risks and rewards, there is then an evidence of legal isolation. evaluation of the transfer of control. Special rules apply for transfers involving Control is considered to be surrendered if the transferee has the practical ability “qualifying” special-purpose entities. to unilaterally sell the transferred asset to a third party, without restrictions. There is no legal isolation test The concept of a qualifying special- purpose entity does not exist. 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. Other differences include: (i) application of sale exception, (v) foreign exchange gain and/ fair value measurement principles, including or losses on AFS investments, (vi) recognition use of prices obtained in ‘principal’ versus of basis adjustments when hedging future ‘most advantageous’ markets, (ii) definitions transactions, (vii) macro hedging, (viii) hedging of a derivative and embedded derivative, net investments, (ix) impairment criteria for (iii) cash flow hedge — basis adjustment and equity investments, (x) puttable minority interest effectiveness testing, (iv) normal purchase and and (xi) netting and offsetting arrangements. 22 US GAAP vs. IFRS The basics
  • 25. Convergence The FASB and the IASB have separate, but related, projects on reducing complexity in The IASB is currently working on a project to this area, with both Boards issuing documents establish a single source of guidance for all fair in 2008. The FASB issued an exposure draft value measurements required or permitted directed at simplifying hedge accounting, and by existing IFRSs to reduce complexity and the IASB issued a discussion paper on reducing improve consistency in their application (similar complexity in reporting financial instruments. to FAS 157). The IASB intends to issue an Additionally, the FASB and the IASB have a joint exposure draft of its fair value measurement project to address the accounting for financial guidance in Q2 of 2009. instruments with characteristics of equity, with a In September 2008, FASB issued a proposed goal of issuing a converged standard by 2011. amendment to FAS 140. The proposed The IASB has a project on its agenda to statement would remove (1) the concept of develop a new standard on derecognition that a qualifying SPE from FAS 140, and (2) the is more consistent with the IASB conceptual exceptions from applying FASB Interpretation framework of financial reporting. Ultimately, No. 46 (revised December 2003) Consolidation the two Boards will seek to issue a converged of Variable Interest Entities to qualifying SPEs. derecognition standard. US GAAP vs. IFRS The basics 23
  • 26. Foreign currency matters Similarities income. Once a subsidiary’s financial statements are remeasured into its functional currency, both FAS 52 Foreign Currency Translation and IAS standards require translation into its parent’s 21 The Effects of Changes in Foreign Exchange functional currency with assets and liabilities Rates are quite similar in their approach being translated at the period-end rate, and to foreign currency translation. While the income statement amounts generally at the guidance provided by each for evaluating the average rate, with the exchange differences functional currency of an entity is different, reported in equity. Both standards also permit it generally results in the same determination the hedging of that net investment with exchange (that is, the currency of the entity’s primary differences from the hedging instrument economic environment). Both GAAPs offsetting the translation amounts reported generally consider the same economies to be in equity. The cumulative translation amounts hyperinflationary, although the accounting for reported in equity are reflected in income an entity operating in such an environment can when there is a sale, or complete liquidation be very different. or abandonment of the foreign operation, but Both GAAPs require foreign currency there are differences between the two standards transactions of an entity to be remeasured into when the investment in the foreign operation is its functional currency with amounts resulting reduced through dividends or repayment of long- from changes in exchange rates being reported in term advances as indicated below. Significant differences US GAAP IFRS Translation/functional Local functional currency financial Local functional currency financial currency of foreign statements are remeasured as if the statements (current and prior period) operations in a functional currency was the reporting are indexed using a general price index, hyperinflationary currency (US dollar in the case of a and then translated to the reporting economy US parent) with resulting exchange currency at the current rate. differences recognized in income. Treatment of translation Translation difference in equity is A return of investment (for example, difference in equity recognized in income only upon dividend) is treated as a partial disposal when a partial return of sale (full or partial), or complete of the foreign investment and a a foreign investment is liquidation or abandonment of the proportionate share of the translation made to the parent foreign subsidiary. No recognition is difference is recognized in income. made when there is a partial return of investment to the parent. 24 US GAAP vs. IFRS The basics
  • 27. US GAAP IFRS Consolidation of foreign The “step-by-step” method is used The method of consolidation is not operations whereby each entity is consolidated specified and, as a result, either the into its immediate parent until the ”direct” or the “step-by-step” method ultimate parent has consolidated the is used. Under the “direct” method, financial statements of all the entities each entity within the consolidated below it. group is directly consolidated into the ultimate parent without regard to any intermediate parent. The choice of method could affect the cumulative translation adjustments deferred within equity at intermediate levels, and therefore the recycling of such exchange rate differences upon disposal of an intermediate foreign operation. Convergence No convergence activities are underway or planned for foreign currency matters. US GAAP vs. IFRS The basics 25
  • 28. Leases Similarities Under both GAAPs, a lessee would record a capital (finance) lease by recognizing an asset The overall accounting for leases under and a liability, measured at the lower of the US GAAP and IFRS (FAS 13 Accounting for present value of the minimum lease payments Leases and IAS 17 Leases, respectively) is or fair value of the asset. A lessee would record similar, although US GAAP has more specific an operating lease by recognizing expense application guidance than IFRS. Both focus on a straight-line basis over the lease term. on classifying leases as either capital (IAS 17 Any incentives under an operating lease are uses the term “finance”) or operating, and amortized on a straight line basis over the term both separately discuss lessee and lessor of the lease. accounting. Lessor accounting Lessee accounting (excluding real estate) (excluding real estate) Lessor accounting under FAS 13 and IAS 17 is Both standards require the party that bears similar and uses the above tests to determine substantially all the risks and rewards of whether a lease is a sales-type/direct financing ownership of the leased property to recognize lease or an operating lease. FAS 13 specifies a lease asset and corresponding obligation, and two additional criteria (that is, collection of specify criteria (FAS 13) or indicators (IAS 17) lease payments is reasonably expected and no to make this determination (that is, whether important uncertainties surround the amount a lease is capital or operating). The criteria of unreimbursable costs to be incurred by the or indicators of a capital lease are similar in lessor) for a lessor to qualify for sales-type/ that both standards include the transfer of direct financing lease accounting that IAS 17 ownership to the lessee at the end of the lease does not have. Although not specified in IAS term and a purchase option that, at inception, 17, it is reasonable to expect that if these is reasonably expected to be exercised. Further, conditions exist, the same conclusion may be FAS 13 requires capital lease treatment if the reached under both standards. If a lease is a lease term is equal to or greater than 75% sales-type/direct financing lease, the leased of the asset’s economic life, while IAS 17 asset is replaced with a lease receivable. If a requires such treatment when the lease term lease is classified as operating, rental income is a “major part” of the asset’s economic life. is recognized on a straight-line basis over the FAS 13 specifies capital lease treatment if the lease term and the leased asset is depreciated present value of the minimum lease payments by the lessor over its useful life. exceeds 90% of the asset’s fair value, while IAS 17 uses the term “substantially all” of the fair value. In practice, while FAS 13 specifies bright lines in certain instances (for example, 75% of economic life), IAS 17’s general principles are interpreted similarly to the bright line tests. As a result, lease classification is often the same under FAS 13 and IAS 17. 26 US GAAP vs. IFRS The basics
  • 29. Significant differences US GAAP IFRS Lease of land and A lease for land and buildings that The land and building elements of building transfers ownership to the lessee or the lease are considered separately contains a bargain purchase option when evaluating all indicators unless would be classified as a capital lease the amount that would initially be by the lessee, regardless of the relative recognized for the land element is value of the land. immaterial, in which case they would be treated as a single unit for purposes If the fair value of the land at inception of lease classification. There is no 25% represents 25% or more of the total test to determine whether to consider fair value of the lease, the lessee the land and building separately when must consider the land and building evaluating certain indicators. 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 If the seller does not relinquish more Gain or loss is recognized immediately, gain or loss on a sale than a minor part of the right to use the subject to adjustment if the sales price and leaseback when asset, gain or loss is generally deferred differs from fair value. the leaseback is an and amortized over the lease term. operating leaseback If 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 seller’s 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 where the seller does not over the lease term. when the leaseback is a relinquish more than a minor part of capital leaseback the right to use the asset. US GAAP vs. IFRS The basics 27
  • 30. Other differences include: (i) the treatment Convergence of a leveraged lease by a lessor under FAS 13 The Boards are jointly working on a long-term (IAS 17 does not have such classification), convergence project on lease accounting (ii) real estate sale-leasebacks, (iii) real estate with an overall objective of comprehensively sales-type leases, and (iv) the rate used to reconsidering the existing guidance issued discount minimum lease payments to the by both standard setters. The Boards have present value for purposes of determining lease tentatively decided to defer the development of classification and subsequent recognition of a a new accounting model for lessors and to adopt capital lease, including in the event of a renewal. an approach that would apply the existing capital lease model, adapted as necessary, to all leases. A joint discussion paper is planned to be issued in the first quarter of 2009, with the Boards then moving towards publication of an exposure draft. 28 US GAAP vs. IFRS The basics
  • 31. Income taxes Similarities Significant differences and FAS 109 Accounting for Income Taxes and convergence IAS 12 Income Taxes provide the guidance The IASB is expected to publish an exposure for income tax accounting under US GAAP draft to replace IAS 12 in 2009 that will eliminate and IFRS, respectively. Both pronouncements certain of the differences that currently exist require entities to account for both current tax between US GAAP and IFRS. The table below effects and expected future tax consequences highlights the significant differences in the of events that have been recognized (that is, current literature, as well as the expected deferred taxes) using an asset and liability proposed accounting under the IASB’s approach. Further, deferred taxes for temporary exposure draft. While initially participating in differences arising from non-deductible goodwill the deliberations on this proposed standard, are not recorded under either approach, and the FASB decided to suspend deliberations on tax effects of items accounted for directly in this project until the IASB issues its exposure equity during the current year also are allocated document on the proposed replacement to directly to equity. Finally, neither GAAP permits IAS 12 for public comment. The FASB is expected the discounting of deferred taxes. to solicit input from US constituents regarding the IASB’s proposed replacement to IAS 12 and then determine whether to undertake a project to fully eliminate the differences in the accounting for income taxes by adopting the revised IAS 12. US GAAP IFRS IASB exposure draft Tax basis Tax basis is a question of Tax basis is generally the IFRS is expected to fact under the tax law. amount deductible or propose a new definition For most assets and taxable for tax purposes. for tax basis that will liabilities there is no The manner in which eliminate consideration dispute on this amount; management intends of management’s intent however, when uncertainty to settle or recover the in determination of the exists it is determined in carrying amount affects tax basis. accordance with FIN 48 the determination of tax Accounting for Uncertainty basis. in Income Taxes. US GAAP vs. IFRS The basics 29