ifrs vs us gaap - international business

7/27/2019 IFRS vs US GAAP - International Business

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In February 2010, the Securities and Exchange

Commission (SEC) published a statement o continued

support or a single set o high quality global accounting

standards and acknowledged that International Financial

Reporting Standards (IFRS) is best positioned to serve

that role. In May 2011, the SEC published a sta paper

exploring one possible method to incorporate IFRS into

the United States (U.S.) nancial reporting system. The

sta paper discussed a potential transition method, the

role o the SEC and Financial Accounting Standards

Board (FASB), and the perceived benets and risks o the

possible method. It did not discuss an option to voluntarily

adopt ull IFRS into the U.S. nancial reporting system.

On July 13, 2012, the SEC released a nal sta report

providing a thorough discussion o the issues related

to IFRS in the U.S., noting that a wholesale switch to

IFRS would strain the resources o U.S. companies

and that a stepped transition has more public support.

The report purposely omits any recommended action

plan. It is expected that the sta will, however, make

a recommendation to the commission at some later,

undetermined date. That means theres no timetable

whatsoever on an SEC decision on IFRS. However, the

continued convergence o IFRS and U.S. GAAP requires

a state o readiness by companies to adopt standards

that are increasingly similar to IFRS.

Currently, a number o new accounting standards are under

development that will urther the eorts o convergence o

U.S. generally accepted accounting principles (U.S. GAAP)

and IFRS. Convergence will have an eect on areas such

as nancial instruments, revenue and leasing.

The table below summarizes the IASB and FASB joint

projects and expected time lines.

In this publication we provide a high level overview o key

dierences between U.S. GAAP and IFRS. While this

publication does not cover every dierence between IFRS

and U.S. GAAP, it ocuses on those dierences generally

considered to be the most signicant or most common.

In addition to providing an overview o key dierences

between U.S. GAAP and IFRS, this publication highlights

some o the issues that U.S. companies will need to

consider on convergence or adoption o IFRS and a

suggested conversion methodology to help U.S. companies

understand the processes that should be considered and

to plan or convergence or adoption o IFRS.

Joint Projects H1 2012 H2 2012

Financial instruments classication & measurement Redeliberations Final standard expected

Financial instruments - impairment Redeliberations Final standard expected

Financial instruments - hedging Redeliberations Redeliberations

Revenue recognition Redeliberations Final standard expected

Leases Redeliberations Final standard expected

Introduction

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contents

How will it aect your company?We highlight some o the issues that companies will need toconsider on convergence or adoption o IFRS

What are the key dierencesbetween U.S. GAAP and IFRS?We provide an overview o the most signifcant dierencesbetween U.S. GAAP and the proposed IFRS standards

What action should be taken?We outline PKFIs suggested conversion methodology to helpcompanies plan or convergence

ARE YOU READY FOR IFRS? 3ARE YOU READY FOR IFRS? 3


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How will it aectyour company?

We highlight some o the issues that companies willneed to consider on convergence or adoption o IFRS

ARE YOU READY FOR IFRS? 44ARE YOU READY FOR IFRS?


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Balance sheet osetting assets and liabilities

IFRS U.S. GAAP

A right o seto is a debtors legal right, by contract or

otherwise, to settle or otherwise eliminate all or a portion

o an amount due to a creditor by applying against that

amount an amount due rom the creditor. Two conditions

must exist or an entity to oset a nancial asset and a

nancial liability (and thus present the net amount on the

balance sheet). The entity must both:

Currently have a legally enorceable right to set o the

recognized amounts

Intend either to settle on a net basis or to realize the

asset and settle the liability simultaneously.

In unusual circumstances, a debtor may have a legalright to apply an amount due rom a third party against

the amount due to a creditor, provided that there is

an agreement among the three parties that clearly

establishes the debtors right o seto.

Master netting arrangements do not provide a basis

or osetting unless both o the criteria described earlier

have been satised. I both criteria are met, osetting is

required.

It is a general principle o accounting that the osetting

o assets and liabilities in the balance sheet is improper

except where a right o oset exists. A right o oset is a

debtors legal right, by contract or otherwise, to discharge

all or a portion o the debt owed to another party by

applying against the debt an amount that the other party

owes to the debtor. A debtor having a valid right o oset

may oset the related asset and liability and report the net

amount. A right o oset exists when all o the ollowing

conditions are met:

Each o two parties owes the other determinable

amounts

The reporting party has the right to oset the amount

owed with the amount owed by the other party

The reporting party intends to oset

The right o oset is enorceable by law.

Repurchase agreements and reverse-repurchase

agreements that meet certain conditions are permitted,

but not required, to be oset in the balance sheet.

There is an exception to the previously described intent

condition or derivative instruments executed with the

same counterparty under a master netting arrangement.

An entity may oset:

1) Fair value amounts recognized or derivative

instruments; and

2) Fair value amounts recognized or the right to reclaim

cash collateral or the obligation to return cash collateral

arising rom derivative instruments recognized at air

value. Entities must adopt an accounting policy to

oset air value amounts under this guidance and apply

that policy consistently

Financial Statement Presentation (continued)

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Balance sheet classied balance sheets

IFRS U.S. GAAP

The presentation o a classied balance sheet is required,

except when a liquidity presentation is more relevant.

The presentation o a classied balance sheet is required,

with the exception o certain industries such as real estate.

Balance sheet classication post balance sheet renancing agreements

IFRS U.S. GAAP

I completed ater the balance sheet date, neither an

agreement to renance or reschedule payments on a long

term basis nor the negotiation o a debt covenant waiver

would result in non-current classication o debt, even i

executed beore the nancial statements are issued.

Entities may classiy debt instruments due within the next

12 months as non-current at the balance sheet date

provided that agreements to renance or to reschedule

payments on a long term basis are completed beore the

nancial statements are issued.

The reporting entity may be able to classiy the obligationas long-term i a private entity is out o compliance with its

debt covenants as at the end o its reporting period and

the violation is waived/resolved by the creditor prior to the

nancial statements being issued or available to be issued.

Balance sheet classication renancing counterparty

IFRS U.S. GAAP

I an entity expects and has the discretion to renance or

roll an obligation or at least 12 months ater the reporting

period under an existing loan nancing, it classies the

obligation as non-current, even i it would otherwise be

due within a shorter period.

The renancing should be with the same counterparty.

A short term obligation may be excluded rom current liabilities

i the entity intends to renance the obligation on a long term

basis and the intent to renance on a long term basis is

supported by an ability to consummate the renancing as

demonstrated by meeting certain requirements.

The renancing does not need to be with the same

counterparty.

Statements o changes in equity

IFRS U.S. GAAP

A statement o changes in equity is presented as a

primary statement or all entities.

Statement o changes in shareholders equity are

presented either as a primary statement or within the

notes to the nancial statements.

Financial Statement Presentation (continued)



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Consolidated nancial statements

IFRS U.S. GAAP

These are generally required i criteria under IAS 27 are

met and, rom 1 January 2013, criteria under IFRS 10 will

be required to be met.

Parent entities prepare consolidated nancial statements

that include all subsidiaries. An exemption applies to a

parent entity when all o the ollowing conditions apply:

It is wholly owned or the owners o the minority interests

have been inormed about and do not object to the

parent not presenting consolidated nancial statements

The parents debt or equity securities are not publicly

traded and the parent is not in the process o issuing

securities in public securities marketsThe immediate or ultimate parent publishes consolidated

nancial statements that comply with IFRS.

The guidance applies to legal structures.

Industry-specic guidance precludes consolidation o

controlled entities by certain types o organizations such

as registered investment companies or broker/dealers.

Consolidated nancial statements are presumed to be

more meaningul and are required or SEC registrants.

There are no exemptions or consolidating subsidiaries in

general purpose nancial statements.

Consolidation model

IFRS U.S. GAAP

This ocuses on the concept o control in determining

whether a parent-subsidiary relationship exists. Control is

the parents ability to govern the nancial and operating

policies o a subsidiary to obtain benets. Control is

presumed to exist when a parent owns, directly or

indirectly, more than 50 per cent o an entitys voting

power. Control also exists when a parent owns hal orless o the voting power but has legal or contractual rights

to control either the majority o the entitys voting power

or the board o directors. Control may exist even in cases

where an entity owns little or none o a special purpose

entitys (SPE) equity. In each case, the application o the

control concept requires judgement in the context o all

relevant actors.

All consolidation decisions are evaluated rst under the

variable interest entities (VIE) model. This requires an entity

with a variable interest in a VIE to qualitatively assess the

determination o the primary beneciary o the VIE.

In applying the qualitative model, an entity is deemed to

have a controlling nancial interest i it meets both o the

ollowing criteria:

Power to direct activities o the VIE that most

signicantly aect the VIEs economic perormance

(power criterion

Obligation to absorb losses rom or right to receive

benets o the VIE that could potentially be signicant

to the VIE (losses/benets criterion).

Consolidations & Joint Venture Accounting



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Consolidation model continued

IFRS U.S. GAAP

When control o an SPE is not apparent, IFRS

requires evaluation o the entity, based on the entitys

characteristics as a whole, to determine the controlling

party. The concept o having rights to the majority o the

economic benets and residual risks is just one part o the

analysis. Other actors considered in the evaluation are

whether the activities o the SPE are being conducted on

behal o the entity. I the entity has decision-making powers

to obtain the majority o the SPEs benets or has delegated

its decision making, the substance o the arrangement

would be considered in order to decide the controlling

party or IFRS purposes.

(The dierences here do not incorporate the new

standard IFRS 10 Consolidated Financial Statements.)

In assessing whether an enterprise has a controlling

nancial interest in an entity, it should consider the entitys

purpose and design, including the risks that the entity

was designed to create and pass through to its variable

interest holders.

Only one enterprise, i any, is expected to be identied as

the primary beneciary o a VIE. Although more than one

enterprise could meet the losses/benets criterion, only

one enterprise, i any, will have the power to direct the

activities o a VIE that most signicantly aects the entitys

economic perormance.

Equity method investments

IFRS U.S. GAAP

IAS 28 Investments in Associates requires investors (other

than venture capital organizations, mutual unds, unit

trusts and similar entities) to use the equity method o

accounting in the consolidated nancial statements.

For separate nancial statements, investments in

subsidiaries and associates can be accounted or either

at cost or air value.

ASC 825-10Financial Instruments gives entities the

option to account or equity-method investments at air

value.

For equity-method investment which management

does not use the air value option, the equity method o

accounting is required.

Consolidations & Joint Venture Accounting(continued)



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Business combinations

Measurement o non-controlling interest

IFRS U.S. GAAP

Non-controlling interest is measured either at air value,

including goodwill, or its proportionate share o the air

value o the acquirees identiable net assets, exclusive

o goodwill.

Non-controlling interest is measured at air value which

includes the non-controlling interests share o goodwill.

Assets and liabilities arising rom contingencies

IFRS U.S. GAAP

Initial Recognition

Contingent liabilities are recognized as o the acquisition

date i there is a present obligation that arises rom

past events and its air value can be measured reliably.Contingent assets are not recognized.

Subsequent Measurement

Contingent liabilities are subsequently easured at the

higher o its acquisition date air value less, i appropriate,

cumulative amortization recognized in accordance with

IAS 18,Revenue, or the amount that would be recognized

i applying IAS 37,Provisions, Contingent Liabilities and

Contingent Assets.

Initial Recognition

Assets and liabilities arising rom contingencies are

recognized at air value in accordance with ASC 820

Fair Value Measurement and Disclosures (ormerlyFAS 157) i the air value can be determined during the

measurement period. I the air value o a contingent asset

or liability cannot be determined during the measurement

period, that asset or liability should be recognized

at the acquisition date in accordance with ASC 450

Contingencies (ormerly FAS 5 and FIN 14) i it meets the

criteria or recognition in that guidance. Contingentassets

and liabilities that do not meet the recognition criteria

at the acquisition date are subsequently accounted or

pursuant to other literature, including ASC 450. (See

Provisions and Contingencies or dierences between

ASC 450 and IAS 37.)

Subsequent Measurement

I contingent assets and liabilities are initially recognized at

air value, an acquirer should develop a systematic and

rational basis or subsequently measuring and accounting

or assets and liabilities arising rom contingencies

depending on their nature.

I amounts are initially recognized and measured under

the contingencies guidance in ASC 450, the subsequent

accounting and measurement should be based on the

same guidance.



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Business combinations (continued)

Acquiree operating leases

IFRS U.S. GAAP

Separate recognition o an intangible asset or liability is

required only i the acquiree is a lessee. I the acquiree

is a lessor, the terms o lease are taken into account in

estimating the air value o the asset subject to the lease.

I the terms o an acquiree operating lease are avourable

or unavourable relative to market terms, the acquirer

recognizes an intangible asset or liability, respectively,

regardless o whether the acquiree is the lessor or

the lessee.



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Impairment o Property, Plant & Equipment(PPE), Goodwill and Intangible AssetsMethod o determining impairment or PPE

IFRS U.S. GAAP

One-step approach requires that impairment testing be

perormed i impairment indicators exist.

Two-step approach requires that a recoverability test be

perormed rst (carrying amount o the asset is compared

to the sum o uture undiscounted cash fows generated

through use and eventual disposition). I it is determined

that the asset is not recoverable, impairment testing must

be perormed.

Impairment loss calculation or PPE

IFRS U.S. GAAP

This is the amount by which the carrying amount o the

asset exceeds its recoverable amount. The recoverable

amount is the higher o: (1) air value less costs to sell,

and (2) value in use (the present value o uture cash fows

in use including disposal value).

This is the amount by which the carrying amount o the

asset exceeds its air value, as calculated in accordance

with ASC 820 (ormerly FAS 157).

Allocation o goodwill

IFRS U.S. GAAP

Goodwill is allocated to a cash-generating unit (CGU)

or group o CGUs which represents the lowest level

within the entity at which the goodwill is monitored or

internal management purposes and cannot be larger than

an operating segment as dened in IFRS 8 Operating

Segments.

Goodwill is allocated to a reporting unit which is an

operating segment or one level below an operating

segment (component).



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Method o determining impairment or goodwill

IFRS U.S. GAAP

One-step approach requires that an impairment test be

done at the CGU level by comparing the CGUs carrying

amount, including goodwill, with its recoverable amount.

A reporting entity may rst assess qualitative actors

to determine i it is necessary to perorm the two step

impairment test (as detailed below). The two step test is

necessary i it is likely that the air value o the reporting

unit is less than its carrying amount.

The two-step approach requires a recoverability test to be

perormed rst at the reporting unit level (carrying amount

o the reporting unit is compared to the reporting unit air

value). I the carrying amount o the reporting unit exceeds

its air value, then impairment testing must be perormed.

Impairment loss calculation or goodwill

IFRS U.S. GAAP

Impairment loss on the CGU (amount by which the

CGUs carrying amount, including goodwill, exceeds its

recoverable amount) is allocated rst to reduce goodwill

to zero. Then, subject to certain limitations, the carrying

amount o other assets in the CGU are reduced pro rata,

based on the carrying amount o each asset.

This is the amount by which the carrying amount o

goodwill exceeds the implied air value o the goodwill

within its reporting unit.

Impairment loss calculation or indenite lived intangible assets

IFRS U.S. GAAP

This is the amount by which the carrying value o the

asset exceeds its recoverable amount.

This is the amount by which the carrying value o the

asset exceeds its air value.

Reversal o impairment loss

IFRS U.S. GAAP

This is prohibited or goodwill. PPE must be reviewed

annually or reversal indicators. I appropriate, loss may be

reversed up to the newly estimated recoverable amount,

not to exceed the initial carrying amount adjusted or

depreciation.

This is prohibited or all assets to be held and used.

Impairment o Property, Plant & Equipment (PPE),Goodwill and Intangible Assets (continued)



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Tax basis

IFRS U.S. GAAP

Tax basis is generally the amount deductible or taxable

or tax purposes. The manner in which management

intends to settle or recover the carrying amount aects the

determination o tax basis.

Tax basis is a question o act under the tax law. There

is no dispute on this amount or most assets and

liabilities but, when uncertainty exists, it is determined in

accordance with ASC 740-10-25 (ormerly FIN 48).

Uncertain tax positions

IFRS U.S. GAAP

IFRS does not include specic guidance. IAS 12 Income

Taxes indicates that tax assets and liabilities should be

measured at the amount expected to be paid. Some adopt

a one-step approach which recognizes all uncertain tax

positions at an expected value. Others adopt a two-

step approach which recognizes only those uncertain

tax positions that are considered more likely than not

to result in a cash outfow. Practice varies regarding the

consideration o detection risk in the analysis.

ASC 740-10-25 requires a two-step process, separating

recognition rom measurement. A benet is recognized

when it is more likely than not to be sustained based on

the technical merits o the position. The amount o benet

to be recognized is based on the largest amount o tax

benet that is greater than 50% likely o being realized

upon ultimate settlement. Detection risk is precluded rom

being considered in the analysis.

Initial recognition exemption

IFRS U.S. GAAP

Deerred tax eects arising rom the initial recognition o an

asset or liability are not recognized when (1) the amounts did

not arise rom a business combination and (2) the transaction

aects neither accounting nor taxable prot (or example,

acquisition o non-deductible assets) upon occurrence.

This does not include an exemption like that under IFRS

or non-recognition o deerred tax eects or certain

assets or liabilities.

Recognition o deerred tax assets

IFRS U.S. GAAP

Amounts are recognized only to the extent it is probable

(similar to more likely than not under U.S. GAAP) that they

will be realized.

Recognized in ull (except or certain outside basis

dierences) but valuation allowance reduces asset to

the amount that is more likely than not to be realized.

Calculation o deerred tax asset or liability

IFRS U.S. GAAP

Enacted or substantively enacted tax rates as o the

balance sheet date must be used.

Enacted tax rates must be used.

Income taxes



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Intangible Assets

Development costs

IFRS U.S. GAAP

Development costs are capitalized when technical and

economic easibility o a project can be demonstrated i

these all under the criteria highlighted.

Some o these criteria are to demonstrate technical

easibility, intention to complete the asset, and the ability

to sell the asset at a uture date.

Development costs are expensed as incurred unless these

are addressed by another standard. Development costs

related to computer sotware developed or external use

are capitalized once technological easibility is established

in accordance with the criteria under ASC 985-20.

In the case o sotware developed or internal use, only

those costs incurred during the development stage

as dened under ASC 350-40Internal Use Sotware

(ormerly SOP 98-1) may be capitalized.

Advertising costs

IFRS U.S. GAAP

Advertising and promotional costs are expensed as

incurred. A prepayment may be recognized as an asset

only when payment or the goods or services is made

in advance o the entitys having access to the goods or

receiving the services.

Advertising and promotional costs are either expensed as

incurred or expensed when the advertising takes place or

the rst time (policy choice). Direct response advertising

may be capitalized i the specic criteria in ASC 340-20

Capitalized Advertising Costs (ormerly SOP 93-7) are met.

Revaluation

IFRS U.S. GAAP

Revaluation to air value o intangible assets other than

goodwill is allowed.

Revaluation is not allowed.



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Costing methods

IFRS U.S. GAAP

LIFO is not allowed. LIFO is allowed.

Measurement

IFRS U.S. GAAP

Inventory is carried at the lower o cost or net realizable

value (best estimate o the net amounts inventories are

expected to realize). This amount may or may not equal

air value.

Inventory is carried at the lower o cost or market. Market

is dened as current replacement cost as long as market

is not greater than net realizable value (estimated selling

price less reasonable costs o completion and sale) and

is not less than net realizable value reduced by a normal

sales margin.

Reversal o inventory write-downs

IFRS U.S. GAAP

Previously recognized impairment losses are reversed up

to the amount o the original impairment loss.

Write downs o inventory to the lower o cost or

replacement cost will create a new cost basis that |

cannot be reversed.

Inventory



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Compound (hybrid) nancial instruments

IFRS U.S. GAAP

Compound (hybrid) nancial instruments need to be split

into debt and equity components and, i applicable, a

derivative component. The derivative component may be

subjected to air value accounting.

Compound (hybrid) nancial instruments (or example,

convertible bonds) are not split into debt and equity

components unless certain specic conditions are met

but they may be biurcated into debt and derivative

components, with the derivative component subjected to

air value accounting.

Impairment recognition Available-or-Sale (AFS) debt instrument

IFRS U.S. GAAP

Generally, only evidence o credit deault results in the

impairment o an AFS debt instrument.Impairment losses recognized through the income

statement or available-or-sale equity securities cannot

be reversed through the income statement or uture

recoveries. However, impairment losses or debt

instruments classied as available-or-sale may be

reversed through the income statement i the air value

o the asset increases in the subsequent period and the

increase can be objectively related to an event occurring

ater the impairment loss was recognized.

Declines in air value below cost may result in an

impairment loss being recognized in the incomestatement on an AFS debt instrument due solely to a

change in interest rates (risk-ree or otherwise) i the entity

has the intent to sell the debt instrument or it is more likely

than not that it will be required to sell the debt instrument

beore its anticipated recovery. In this circumstance,

the impairment loss is measured as the dierence

between the debt instruments amortized cost basis and

its air value.

Hedge eectiveness shortcut method or interest rate swaps

IFRS U.S. GAAP

Not permitted. Permitted.

Financial Instruments (Under IAS 39 and notIFRS 9 - eective rom 1 January 2015) - (continued)



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Foreign Currency

Translation/unctional currency o oreign operations in a hyperinfationary economy

IFRS U.S. GAAP

Financial statements (current and prior periods) in local

unctional currency are indexed by using a general price

index and then translated into the reporting currency at

the current rate.

Local unctional currency nancial statements are re-

measured as i the unctional currency was the reporting

currency (U.S. dollar in the case o a U.S. parent) with

resulting exchange dierences recognized in income.

Net investment denominated in currencies other than the unctional currencies o the entities

that are parties to the monetary items

IFRS U.S. GAAP

IFRS does not require monetary items to be denominated

in unctional currencies o the entities that are parties to the

monetary item in order or it to be accounted or as a part

o the reporting entitys net investment in those entities.

Foreign currency transactions between the entities within

same group, or which settlement is neither planned

nor likely to occur in the oreseeable uture, may be

considered a part o the net investment i the monetaryitems are denominated in the unctional currencies o the

entities that are parties to the monetary items.

Consolidation o oreign operations

IFRS U.S. GAAP

The method o consolidation is not specied and, as a

result, either the direct or the step-by-step method

is used. Under the direct method, each entity within

the consolidated group is directly consolidated into

the ultimate parent without regard to any intermediate

parent. The choice o a method could aect the

cumulative translation adjustments deerred within equityat intermediate levels and, thereore, the recycling o

such exchange rate dierences upon disposal o an

intermediate oreign operation.

A bottom-up approach is required in order to refect

the appropriate oreign currency eects and hedges in

place. As such, an entity should be consolidated by the

enterprise that controls the entity. Thereore, the step-

by-step method o consolidation is used whereby each

entity is consolidated into its immediate parent until the

ultimate parent has consolidated the nancial statementso all the entities below it.



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Share-based payments

Transactions with non-employees

IFRS U.S. GAAP

The air value o a transaction should be based on the

value o the goods or services received and only on the

air value o the equity instruments i the air value o the

goods and services cannot be reliably determined.

The measurement date is the date on which the entity

obtains the goods or the counterparty renders the

services. There is no perormance commitment concept.

Either the air value o (1) the goods or services received,

or (2) the equity instruments is used to value the

transaction, whichever is more reliable.

I using the air value o the equity instruments, ASC 505-

50Equity-Based Payments to Non-Employees (ormerly

EITF 96-18), measurement is required at the earlier o (1)

the date at which a commitment or perormance by

the counterparty is reached, or (2) the date at which the

counterpartys perormance is complete.

Measurement and recognition o expense awards with graded vesting eatures

IFRS U.S. GAAP

This must recognize compensation cost on an

accelerated basis each individual tranche must be

separately measured.

Entities make an accounting policy election to recognize

compensation cost or awards containing only service

conditions either on a straight-line basis or on an

accelerated basis, regardless o whether the air value o

the award is measured based on the award as a whole or

or each individual tranche.

Equity repurchase eatures at an employees choice

IFRS U.S. GAAP

Liability classication is required (no six month

consideration exists).

Does not require liability classication i employee bears

risks and rewards o equity ownership or at least six

months rom the date the equity is issued or vests.



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What actionshould be taken?We outline PKFIs suggested conversion methodologyto help companies plan or convergence

31ARE YOU READY FOR IFRS? 31ARE YOU READY FOR IFRS?


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ifrs vs us gaap - international business

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