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Worldwide Accounting Diversity and International Standards
Chapter Eleven Worldwide Accounting Diversity and International Standards Copyright © 2015 McGraw-Hill Education. All rights reserved. No reproduction or distribution without the prior written consent of McGraw-Hill Education.
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International Accounting Diversity
Chinese companies use the direct method in preparing the statement of cash flows. Companies in Germany are allowed to report assets on the balance sheet at revalued amounts. Most companies in the United States and Europe use the indirect method. Chinese companies use the direct method in preparing the statement of cash flows. Most companies in the United States and Europe use the indirect method.
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Explain the major factors influencing the international
Learning Objective 11-1 Explain the major factors influencing the international development of accounting systems. Explain the major factors influencing the international development of accounting systems.
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Reasons for Accounting Diversity
Legal System Taxation All these interact!!! Political and Economic Ties Culture Financing Systems Inflation
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Reasons for Accounting Diversity- Legal System
Common Law Found primarily in English-speaking countries, where courts establish precedent. Accounting profession plays a large role in standard setting and tends to be independent. Standards tend to be detailed. Common Law Found primarily in English- speaking countries, where courts establish precedent. Accounting profession plays a large role in standard setting and tends to be independent. Standards tend to be detailed.
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Reasons for Accounting Diversity-Legal System
Roman (Codified) Law Based on statute rather than precedent. Laws govern business enterprises. Accounting profession tends to have little influence on standard setting, is frequently an adjunct of the legal system. Accounting law tends to be lacking in detail. Reasons for Accounting Diversity- Legal System Roman (Codified) Law Based on statute rather than precedent. Laws govern business enterprises. Accounting profession tends to have little influence on standard setting, is frequently an adjunct of the legal system. Accounting law tends to be lacking in detail.
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Reasons for Accounting Diversity- Financing Systems
Major providers of financing: Family members Banks Focus on solvency and liquidity (balance sheet emphasis) Governments Shareholders Focus on profitability (income statement emphasis) Other creditors Reasons for Accounting Diversity- Financing Systems Major providers of financing: Family members Banks Focus on solvency and liquidity (balance sheet emphasis) Governments Shareholders Focus on profitability (income statement emphasis) Other creditors
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Reasons for Accounting Diversity- Other Issues
Taxation Financial statements are the basis for taxation in some countries. Others adjust financial statements for tax purposes, and submit separate reports to stockholders’. Inflation High inflation tends to render historical cost useless. High inflation rates force adoption of accounting rules that adjust historical costs to current or market value. Creditors tend to suffer under highly inflationary economies. Reasons for Accounting Diversity- Other Issues Taxation Financial statements are the basis for taxation in some countries. Others adjust financial statements for tax purposes, and submit separate reports to stockholders’. Inflation High inflation tends to render historical cost useless. High inflation rates force adoption of accounting rules that adjust historical costs to current or market value. Creditors tend to suffer under highly inflationary economies.
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Reasons for Accounting Diversity- Political and Economic Ties
Accounting methods are readily conveyed from one country to another, either by trade or conquest: Britain’s former colonies, such as Australia and Canada, tend toward “common law” systems Former French colonies, such as Senegal and Congo, base accounting standards on “codified law” Economic ties with the US have impacted accounting in Canada, Mexico and Israel Reasons for Accounting Diversity- Political and Economic Ties Accounting methods are readily conveyed from one country to another, either by trade or conquest: Britain’s former colonies, such as Australia and Canada, tend toward “common law” systems Former French colonies, such as Senegal and Congo, base accounting standards on “codified law” Economic ties with the US have impacted accounting in Canada, Mexico and Israel
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Reasons for Accounting Diversity- Culture
Societal values found within cultures: Individualism Uncertainty Avoidance Power Distance Masculinity These values are thought to shape legal systems and capital markets. They influence accounting values shared by members of the accounting subculture, which influences the nature of the accounting system. Reasons for Accounting Diversity- Culture Societal values found within cultures: Individualism Uncertainty Avoidance Power Distance Masculinity These values are thought to shape legal systems and capital markets. They influence accounting values shared by members of the accounting subculture, which influences the nature of the accounting system.
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Gray’s Framework for the Development of Accounting Systems Internationally
Cultural Dimensions Individualism Uncertainty Avoidance Power Distance Masculinity Institutional Consequences Legal system Corporate Ownership Capital Markets Professional Associations Education & Religion Cultural Dimensions Individualism Uncertainty Avoidance Power Distance Masculinity Accounting Values Professionalism Uniformity Conservatism Secrecy Institutional Conseq. Legal system Corporate Ownership Capital Markets Professional Associations Education & Religion Accounting Systems Authority Enforcement Measurement Disclosure Accounting Values Professionalism Uniformity Conservatism Secrecy Accounting Systems Authority Enforcement Measurement Disclosure
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Nobes’ Model of the Reasons for International Accounting Diversity
Nobes’ simplified model has two explanatory factors: (1) national culture, including institutional structures, (2) the nature of a country’s financing system divided into two classes. Class A (Strong equity-outsider financing system) Less conservative Greater disclosure Financial and tax accounting separate Class B (Weak equity-outsider financing system) More conservative Less extensive disclosure Financial reporting follows tax rules Nobes’ Model of the Reasons for International Accounting Diversity Nobes’ simplified model has two explanatory factors: (1) national culture, including institutional structures, (2) the nature of a country’s financing system divided into two classes. Class A (Strong equity-outsider financing system) Less conservative Greater disclosure Financial and tax accounting separate Class B (Weak equity-outsider financing system) More conservative Less extensive disclosure Financial reporting follows tax rules
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Understand the problems created by differences in
Learning Objective 11-2 Understand the problems created by differences in accounting standards across countries and the reasons to develop a set of internationally accepted accounting standards. Understand the problems created by differences in accounting standards across countries and the reasons to develop a set of internationally accepted accounting standards.
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Problems Caused By Diverse Accounting Standards
Subs use local standards for financial statements. The parent must adjust the subs’ statements to GAAP. Statements must be re-stated in common standards. To access foreign capital markets, costly measures must be taken to prepare financial statements that comply with local standards. Financial statements from different countries are simply not comparable. Accounting rules differ from country to country. Problems Caused By Diverse Accounting Standards Problems Subs use local standards for financial statements. The parent must adjust the subs’ statements to GAAP. Statements must be re-stated in common standards. To access foreign capital markets, costly measures must be taken to prepare financial statements that comply with local standards. Financial statements from different countries are simply not comparable. Accounting rules differ from country to country.
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International Harmonization
Harmonization: Reducing differences in accounting practices across countries. Harmonization efforts have been ongoing for decades, and originally the International Accounting Standards Committee (IASC) led the movement. In 1987, the International Organization of Securities Commissions (IOSCO) joined the effort. Since 2001, the process has been led by the International Accounting Standards Board (IASB) International Harmonization Harmonization: Reducing differences in accounting practices across countries. Harmonization efforts have been ongoing for decades, and originally the International Accounting Standards Committee (IASC) led the movement . In 1987, the International Organization of Securities Commissions (IOSCO) joined the effort. Since 2001, the process has been led by the International Accounting Standards Board (IASB)
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List the authoritative pronouncements that constitute
Learning Objective 11-3 List the authoritative pronouncements that constitute International Financial Reporting Standards (IFRS). List the authoritative pronouncements that constitute International Financial Reporting Standards (IFRS).
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International Accounting Standards Committee- IASC
International Accounting Standards committee (IASC) established in 1973. IASB superseded IASC in April 2001. 16-member board at least 13 full-time The IASB has sole responsibility for establishing IFRSs (“IASB GAAP”) IASB has no enforcement authority!! International Accounting Standards committee (IASC) established in 1973. IASB superseded IASC in April 16-member board (13 full-time) The IASB has sole responsibility for establishing IFRSs (“IASB GAAP”) IASB has no enforcement authority!!
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International Accounting Standards Board (IASB)
All of the 41 IASs issued by the IASC were adopted by the IASB. 28 are currently in effect. New standards are called “International Financial Reporting Standards” (IFRSs). As of January 2013, 13 IFRSs have been issued. International Accounting Standards Board (IASB) All of the 41 IASs issued by the IASC were adopted by the IASB. 28 are currently in effect. New standards are called “International Financial Reporting Standards” (IFRSs). As of July 2011, 13 IFRSs have been issued.
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Describe the ways and the extent to which IFRS are used
Learning Objective 11-4 Describe the ways and the extent to which IFRS are used around the world. Describe the ways and the extent to which IFRS are used around the world.
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International Financial Reporting Standards (IFRSs)
Countries can elect to use IFRS by: (1) adopting IFRS as its national GAAP (2) requiring domestic listed companies to use IFRS in preparing their consolidated financial statements (3) allowing domestic listed companies to use IFRS (4) requiring or allow foreign companies listed on a domestic stock exchange to use IFRS. International Financial Reporting Standards (IFRSs) Countries can elect to use IFRS by: (1) adopting IFRS as its national GAAP (2) requiring domestic listed companies to use IFRS in preparing their consolidated financial statements (3) allowing domestic listed companies to use IFRS (4) requiring or allow foreign companies listed on a domestic stock exchange to use IFRS.
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International Financial Reporting Standards (IFRSs)
Of the 153 countries using IFRS as of June 2012: (1) 92 require all domestic listed companies to use IFRS in preparing their consolidated financial statements. (2) All publicly traded companies in the EU are required to use IFRS. (3) Two significant exceptions – China and the U.S. International Financial Reporting Standards (IFRSs) Of the 153 countries using IFRS as of June 2012: (1) 92 require all domestic listed companies to use IFRS in preparing their consolidated financial statements. (2) All publicly traded companies in the EU have been required to use IFRS since January 1, 2005. (3) Two significant exceptions – China and the U.S.
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Describe the FASB–IASB
Learning Objective 11-5 Describe the FASB–IASB convergence process and the SEC recognition of IFRS. Describe the FASB–IASB convergence process and the SEC recognition of IFRS.
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Norwalk Agreement: FASB-IASB Convergence
In Norwalk, Connecticut, FASB and IASB held a joint meeting in September 2002. The “Norwalk Agreement” states that the two bodies will “use their best efforts” to: 1. Make existing financial reporting standards compatible “as soon as is practicable” and 2. Coordinate efforts to “ensure that once achieved, compatibility is maintained” Norwalk Agreement: FASB-IASB Convergence In Norwalk, Connecticut, FASB and IASB held a joint meeting in September 2002. The “Norwalk Agreement” states that the two bodies will “use their best efforts” to: 1. Make existing financial reporting standards compatible “as soon as is practicable” and 2. Coordinate efforts to “ensure that once achieved, compatibility is maintained”
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Norwalk Agreement: FASB-IASB Convergence
2006- Memorandum of Understanding (MoU) FASB and IASB agreed that trying to eliminate differences between standards and create identical standards, even if jointly developed, is not realistic. Instead, they agreed that standards in need of improvement should be replaced with new jointly developed standards. The idea behind convergence is to have similar, but not necessarily identical standards. Memorandum of Understanding (MoU) developed in 2006, the FASB and IASB agreed that trying to eliminate differences between two standards that are in need of significant improvement is not a good use of resources. Instead, standards in need of improvement should be replaced with new jointly developed standards. The idea behind convergence is to have similar, but not necessarily identical standards. Indeed, the boards acknowledge that the development of identical standards, even if jointly developed, is not realistic.
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FASB-IASB Convergence
As of January 2013, the FASB‐IASB convergence process had resulted in changes made to U.S. GAAP, IFRS, or both: Business combinations ∙ Borrowing costs Consolidated financial statements ∙ Derecognition Non‐controlling interests ∙ Post‐employment benefits Acquired in‐process research costs ∙ Fair value option Non‐monetary asset exchanges ∙ Joint ventures Share‐based payment ∙ Fair value measurement Accounting changes ∙ Segment reporting Presentation of (OCI) ∙ Inventory accounting As of January 2013, the FASB‐IASB convergence process had resulted in changes made to U.S. GAAP, IFRS, or both in the following areas: Business combinations Consolidated financial statements Non‐controlling interests Acquired in‐process research costs Joint ventures Share‐based payment Accounting changes Inventory accounting Borrowing costs Derecognition Post‐employment benefits Non‐monetary asset exchanges Fair value option Fair value measurement Segment reporting Presentation of other comprehensive income
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FASB-IASB Convergence
As part of its technical agenda at the beginning of 2013, the FASB listed the following on‐going joint convergence projects with either an Exposure Draft or final standard expected to be issued in 2013: Leases Insurance contracts Financial instruments Revenue recognition As part of its technical agenda at the beginning of 2013, the FASB listed the following ongoing joint convergence projects with either an Exposure Draft or final standard expected to be issued in 2013: • Leases • Insurance contracts • Financial instruments • Revenue recognition
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IFRS Roadmap IFRS Roadmap:
In November 2008, SEC issued a proposed rule that set milestones toward the use of IFRS by U.S. public companies by 2014. In February 2010, SEC pushed that date back to “approximately 2015 or 2016.” In reaction to the support expressed for IFRS, the SEC issued a proposed rule for the potential use of IFRS by U.S. public companies in November This so-called IFRS Roadmap sets forth several milestones that, if achieved, could lead to the required use of IFRS by U.S. issuers. The SEC indicated that it would monitor these milestones until 2011, and if significant progress had been made at that time the SEC would then require the mandatory adoption of IFRS by U.S. public companies over a three-year phase-in period. The roadmap indicated 2014 as the first year of IFRS adoption, but a subsequent SEC Release in February 2010 pushed that date back to “approximately 2015 or 2016.”
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IFRS Framework In May 2011, the SEC published a suggested framework for an “endorsement process” incorporating IFRS into U.S. GAAP. The two components of the framework are: (1) FASB continues to participate in the process of developing new IFRSs and incorporates those standards into U.S. GAAP by means of an endorsement process. (2) The FASB would incorporate existing IFRSs into U.S. GAAP over a defined period of time, e.g., five to seven years, with a focus on minimizing transition costs for U.S. companies. However, in May 2011, the SEC published a suggested framework for an “endorsement process” incorporating IFRS into U.S. GAAP. The two components of the framework are: (1) FASB continues to participate in the process of developing new IFRSs and incorporates those standards into U.S. GAAP by means of an endorsement process. (2) The FASB would incorporate existing IFRSs into U.S. GAAP over a defined period of time, e.g., five to seven years, with a focus on minimizing transition costs for U.S. companies.
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IFRS Framework This approach would:
maintain U.S. GAAP, which could continue to be used by both public and nonpublic companies. achieve the objective of having a single set of high- quality, globally accepted accounting standards. retain the FASB’s authority for establishing financial reporting standards in the United States, and provide the flexibility to modify the requirements of IFRS. This approach would maintain U.S. GAAP, which could continue to be used by both public and nonpublic companies. It would achieve the objective of having a single set of high-quality, globally accepted accounting standards. At the same time, it would retain the FASB’s authority for establishing financial reporting standards in the United States, and provide the flexibility to modify the requirements of IFRS
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IFRS Framework Modifications could include:
Requiring additional disclosures beyond what is required by an IFRS. Prescribing which of two or more alternative accounting treatments allowed by IFRS should be followed by U.S. issuers. Promulgating standards on issues not specifically addressed in IFRS. . These modifications could include: • Requiring additional disclosures beyond what is required by an IFRS. • Prescribing which of two or more alternative accounting treatments allowed by IFRS should be followed by U.S. issuers. • Promulgating standards on issues not specifically addressed in IFRS.
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First-time Adoption of IFRS
Large US publicly-traded companies may be required to adopt IFRS someday. What does this mean? The company would prepare an opening balance sheet at the “transition date” and present re-stated comparative statements also prepared under IFRS. Large US publicly-traded companies may be required to adopt IFRS someday. What does this mean? The company would prepare an opening balance sheet the “transition date” and present re-stated comparative statements also prepared under IFRS.
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First-time Adoption of IFRS
Steps To prepare opening IFRS balance sheet: Determine the applicable IFRS. Recognize assets and liabilities not recognized under GAAP and derecognize those not allowed under IFRS. Measure the balance sheet accounts under IFRS at the balance sheet date. Reclassify certain assets and liabilities in accordance with IFRS. Comply with disclosure and presentation requirements. Steps To prepare opening IFRS balance sheet: Determine the applicable IFRS. Recognize assets and liabilities not recognized under GAAP and derecognize those not allowed under IFRS. Measure the balance sheet accounts under IFRS at the balance sheet date. Reclassify certain assets and liabilities in accordance with IFRS. Comply with disclosure and presentation requirements.
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IFRS Accounting Policy Hierarchy
IAS 8, Accounting Policies, Changes in Accounting Estimates and Errors, establishes the hierarchy that firms must follow when dealing with an accounting issue: 1. Apply specifically relevant standards (IASs, IFRSs, or Interpretations). 2. Refer to other IASB standards. 3. Refer to the IASB Framework for guidance. 4. Consider the most recent pronouncements of other standard-setting bodies IAS 8, Accounting Policies, Changes in Accounting Estimates and Errors, establishes the hierarchy that firms must follow when dealing with an accounting issue: 1. Apply specifically relevant standards (IASs, IFRSs, or Interpretations). 2. Refer to other IASB standards. 3. Refer to the IASB Framework for guidance. 4. Consider the most recent pronouncements of other standard-setting bodies
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IFRS Accounting Policy Hierarchy
In establishing accounting policies to be followed under IFRS, the two extreme approaches that companies can follow are: 1. Minimize change. Under this approach a company would adopt accounting policies consistent with IFRS that are most consistent with current accounting policies. 2. Fresh start. Under this approach a company would ignore current accounting policies and adopt accounting policies consistent with the IFRS that best reflect economic reality. In establishing accounting policies to be followed under IFRS, the two extreme approaches that companies can follow are: 1. Minimize change. Under this approach a company would adopt accounting policies consistent with IFRS that are most consistent with current accounting policies. 2. Fresh start. Under this approach a company would ignore current accounting policies and adopt accounting policies consistent with the IFRS that best reflect economic reality.
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Recognize acceptable accounting treatments under IFRS and
Learning Objective 11-6 Recognize acceptable accounting treatments under IFRS and identify key differences between IFRS and U.S. GAAP. Recognize acceptable accounting treatments under IFRS and identify key differences between IFRS and U.S. GAAP.
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Current Differences Between IFRSs and US GAAP
Recognition: If recognized, how? When? Presentation: Principles? Financial Statement Components? Disclosure: If allowed, How? Measurement: How is cost determined? n a comparison of IFRS and U.S. GAAP published by the SEC in November 2011, the SEC Staff identified numerous differences in the two sets of standards across a wide range of topics. E xhibit 11.8 summarizes some of the key differences between IFRS and U.S. GAAP. Note that a number of these differences are within the scope of the FASB– IASB convergence projects and therefore are likely to be eliminated over time. The types of differences that exist between IFRS and U.S. GAAP can be generally classified as follows: 1. Recognition differences Measurement differences Presentation and disclosure differences. Discontinued Operations Extraordinary Items Inventory Fixed Assets
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Current Differences Between IFRSs and US GAAP
There are differences in nearly every area of financial accounting including: Inventory -- cost flow and write-offs PP&E-- measurement and subsequent costs Asset Impairment – measurement and subsequent reversals Construction contracts – recognition method R&D – capitalization vs expense Operating Leases – gain recognition Pensions – vested benefits There are differences in nearly every area of financial accounting including: Inventory -- cost flow and write-offs PP&E-- measurement and subsequent costs Asset Impairment – measurement and subsequent reversals Construction contracts – recognition method R&D – capitalization vs expense Operating Leases – gain recognition
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Current Differences Between IFRSs and US GAAP
Continued… Income taxes – deferred tax assets Classification of deferred taxes Consolidated financial statements – Parent vs. Subsidiary Interim reporting – Discrete vs. integral Presentation of “extraordinary” items Definition of a “discontinued operation” Statement of Cash Flows – Interest classification Continued… Pensions – vested benefits Income taxes – deferred tax assets Classification of deferred taxes Consolidated financial statements – Parent vs. Subsidiary Interim reporting – discrete vs. integral Statement of Cash Flows – interest classification
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IAS 1: Presentation of Financial Statements
IFRSs contain this single standard governing the presentation of financial statements. There is no US GAAP equivalent. Key guidance elements: Purpose Overriding principle of fair presentation Basic principles and assumptions Components of financial statements Structure and content of financial statements IAS 1, “Presentation of Financial Statements” IFRSs contain this single standard governing the presentation of financial statements. There is no US GAAP equivalent. Key guidance elements: Purpose Overriding principle of fair presentation Basic principles and assumptions Components of financial statements Structure and content of financial statements
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Presentation of Financial Statements
IFRS COMPANY Income Statement IAS 1 requires an entity to classify assets and liabilities as current and noncurrent unless presentation according to liquidity provides more reliable information. The income statement can be presented using either a function of expenses (cost of sales) format or a nature of expenses format. Exhibit 11.9 illustrates of the alternative formats for classifying expenses on the income statement. Note that the amount reported as Operating income (loss) is the same under both formats. Additional required disclosures must be made either on the face of the income statement or in the notes. For example, a company using the function of expenses format must disclose additional information on the nature of expenses, including depreciation and amortization expense and employee benefits expense. For both formats, the total amount distributed as dividends as well as dividends per share must be disclosed. In addition, IAS 33, “Earnings per Share,” requires basic and diluted earnings per share to be reported on the face of the income statement.
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Determine the impact that specific differences between
Learning Objective 11-7 Determine the impact that specific differences between IFRS and U.S. GAAP have on the measurement of income and stockholders’ equity. Determine the impact that specific differences between IFRS and U.S. GAAP have on the measurement of income and stockholders’ equity.
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U.S. GAAP Reconciliations
Interest Capitalization Business Combinations Purchase vs. Pooling Methods Goodwill Amortization vs. Impairment Leases Revaluation of Fixed Assets Fixed Asset Impairment Losses U.S. GAAP Reconciliations: Interest Capitalization Business Combinations Purchase vs. Pooling Methods Goodwill Amortization vs. Impairment Leases Revaluation of Fixed Assets Fixed Asset Impairment Losses
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U.S. GAAP Reconciliations
IASB: Principles- Based Provide general principles with limited guidance. Requires greater professional judgment. FASB: Rules-Based Provide detailed guidance. May encourage mindset of looking for loop-holes. IASB: Principles-Based Provide general principles with limited guidance. Requires greater professional judgment. FASB: Rules-Based Provide detailed guidance. May encourage mindset of looking for loop-holes.
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U.S. GAAP Reconciliations
Translation of IFRS into other languages IFRS are drafted in English, then translated into other languages. Time has already proven that some terms (“probable” or “remote”) are not translating with the same meaning. The impact of Culture Using professional judgment under IFRS, an accountant in one country may reach a different conclusion than an accountant in another part of the world. Translation of IFRS into other languages IFRS are drafted in English, then translated into other languages. Time has already proven that some terms (“probable” or “remote”) are not translating with the same meaning. The impact of Culture Using professional judgment under IFRS, an accountant in one country may reach a different conclusion than an accountant in another part of the world.
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