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	<title>Substance Matters &#187; accounting</title>
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	<description>When it comes to cross-border transactions...</description>
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		<title>FASB, We Have a Problem: Why a principles-based accounting standard is the wrong answer for the U.S.</title>
		<link>http://verseconsulting.com/blog/fasb-we-have-a-problem-why-a-principles-based-accounting-standard-is-the-wrong-answer-for-the-u-s/</link>
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		<pubDate>Wed, 09 Dec 2009 15:58:22 +0000</pubDate>
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				<category><![CDATA[IFRS]]></category>
		<category><![CDATA[accounting]]></category>
		<category><![CDATA[accounting standards]]></category>
		<category><![CDATA[capital markets]]></category>
		<category><![CDATA[Congress]]></category>
		<category><![CDATA[enterprise risk management]]></category>
		<category><![CDATA[FASB]]></category>
		<category><![CDATA[financial reporting]]></category>
		<category><![CDATA[financial statement]]></category>
		<category><![CDATA[IASB]]></category>
		<category><![CDATA[tax]]></category>

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		<description><![CDATA[This blog is a continuation of our a series examining the potential ramifications of IFRS adoption for transfer pricing by U.S. multinationals. Given that we are in the middle of the most devastating financial crisis since the Great Depression when there has been a clarion call of epic proportions for greater transparency and more usable [...]]]></description>
			<content:encoded><![CDATA[<p><em>This blog is a continuation of our a series examining the potential ramifications of IFRS adoption for transfer pricing by U.S. multinationals.</em></p>
<p>Given that we are in the middle of the most devastating financial crisis since the Great Depression when there has been a clarion call of epic proportions for greater transparency and more usable financial statement information, why FASB is embracing IFRS – a principles-based set of standards, as opposed to continuing to evolve the U.S. GAAP rules-based system – is beyond belief. Those of us who have been practicing for more than two decades remember the principles-based approach under U.S. GAAP that, with pressure from Congress, the SEC and investors, became rules-based over the past two decades.</p>
<p>Based on the teachings from recent CPE seminars I have attended in the last two weeks, it seems that the accounting standard-setting bodies have run amok. Consider the proposal on lease accounting. Under IFRS and revised U.S. GAAP, the expectation is that operating leases will be eliminated. As a result, lessees will have to capitalize the asset and amortize or depreciate that asset; details to follow later. Conceptually this seems odd as in many instances the lessor clearly retains title to the property and, in the case of commercial real estate, has no intention of conveying same to the lessee. Put differently, the lessor is not necessarily providing financing to the lessee.</p>
<p>Alternatively, consider commercial real estate leases – typically operating leases – where the lessee has a right to occupy the premises owned by the landlord. Now, consider the implications of capitalizing these leases and treating the lessee as having an ownership interest in the property – which in theory implies that the transaction is a form of financing. In point of fact, nothing could be further from the truth. The economic reality, accounting notwithstanding, is that the lessee has an occupancy right to the premises provided payments and lease terms are satisfied. So, how could this be a capitalized asset?</p>
<p>Add on the tax implications of such arrangements, as it is unlikely there will be a basis for arguing that the lessee has a depreciable asset, aside from leasehold improvements. Thus, it seems likely that there will be even more book/tax differences to account for – which adds increased complexity to an already overly complex set of provisions. How does this change help users of the financial statements? It seems that there will be more people required to account for transactions than there are generating revenue and transacting business.</p>
<p>Meaningful financial statement reform must be based on the needs of the end user. The capital markets won’t recover until investors are confident in the information they are receiving. Until balance and incremental change return to the standard-setting process the capital markets will likely remain tepid at best. Unlike the Pirate Code, accounting standards in the U.S. cannot be “more guidelines than actual rules.” FASB needs to rethink the wisdom of moving the U.S. to a principles-based set of standards given the current economic climate and the needs of U.S. businesses and their investors particularly in view of the fact that we have already been down this road.</p>
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