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1、Chapter 11Worldwide accouNting diversityAND international standardsChapter OutlineI.Accounting and financial reporting rules differ across countries. There are a variety of factors influencing a countrys accounting system.A.Legal systemprimarily relates to how accounting principles are established;
2、code law countries generally having legislated accounting principles and common law countries having principles established by non-legislative means. B.Taxationfinancial statements serve as the basis for taxation in many countries. In those countries with a close linkage between accounting and taxat
3、ion, accounting practice tends to be more conservative so as to reduce the amount of income subject to taxation.C.Financing systemwhere shareholders are a major provider of financing, the demand for information made available outside the company becomes greater. In those countries in which family me
4、mbers, banks, and the government are the major providers of business finance, there is less demand for public accountability and information disclosure.D.Inflationhistorically, caused some countries, especially in Latin America, to develop accounting principles in which traditional historical cost a
5、ccounting is abandoned in favor of inflation adjusted figures. As inflation has been brought under control in most countries, this factor is no longer of significant influence.E.Political and economic tiescan explain the usage of a British style of accounting throughout most of the former British Em
6、pire. They also help to explain similarities between the U.S. and Canada, and increasingly, the U.S. and Mexico.F.Cultureaffects a countrys accounting system in two ways: (1) through its influence on a countrys institutions, such as its legal system and system of financing, and (2) through its influ
7、ence on the accounting values shared by members of the accounting sub-culture. II.Nobes developed a general model of the reasons for international differences in financial reporting that has only two explanatory factors: (1) national culture, including institutional structures, and (2) the nature of
8、 a countrys financing system. A.A self-sufficient Type I culture will have a strong equity-outsider financing system which results in a Class A accounting system oriented toward providing information for outside shareholders.B.A self-sufficient Type II culture will have a weak equity-outsider financ
9、ing system which results in a Class B accounting system oriented toward protecting creditors and providing a basis for taxation.C.Countries dominated by a country with a Type I culture will use a Class A accounting system even though they do not have strong equity-outsider financing systems. D.Compa
10、nies with strong equity-outsider financing located in countries with a Class B accounting system will voluntarily attempt to use a Class A accounting system to compete in international capital markets. III.Differences in accounting across countries cause several problems.A.Consolidating foreign subs
11、idiaries requires that the financial statements prepared in accordance with foreign GAAP must be converted into the parent companys GAAP.B.Companies interested in obtaining capital in foreign countries often are required to provide financial statements prepared in accordance with accounting rules in
12、 that country, which are likely to differ from rules in the home country.C.Investors interested in investing in foreign companies may have a difficult time in making comparisons across potential investments because of differences in accounting rules across countries.IV.The International Accounting S
13、tandards Committee (IASC) was formed in 1973 in hopes of improving and promoting the worldwide harmonization of accounting principles. It was superseded by the International Accounting Standards Board (IASB) in 2001.A.The IASC issued 41 International Accounting Standards (IAS) covering a broad range
14、 of accounting issues. Ten IASs have been superseded or withdrawn, leaving 31 in effect.B.The membership of the IASC was composed of over 140 accountancy bodies from more than 100 nations.C.The IASC was not in a position to enforce its standards. Instead, member accountancy bodies pledged to work to
15、ward acceptance of IASs in the respective countries. D.Because of criticism that too many options were allowed in its standards and therefore true comparability was not being achieved, the IASC undertook a Comparability Project in the 1990s, revising 10 of its standards to eliminate alternatives.E.T
16、he IASC derived much of its legitimacy as an international standard setter through endorsement of its activities by the International Organization of Securities Commissions. IOSCO and the IASC agreed that, if the IASC could develop a set of core standards, IOSCO would recommend that stock exchanges
17、allow foreign companies to use IASs in preparing financial statements. The IASC completed the set of core standards in 1998, IOSCO endorsed their usage by foreign companies in 2000, and many members of IOSCO adopted this recommendation.V.The International Accounting Standards Board (IASB) replaced t
18、he IASC in 2001. A.The IASB originally consisted of 14 members 12 full-time and 2 part-time. The number of board members was increased to 16 members in 2012, at least 13 of whom must be full-time. Full-time IASB members are required to sever their relationships with former employers to ensure indepe
19、ndence. To ensure a broad international diversity, there normally are four members from Europe; four from North America; four from the Asia/Oceania region; one from Africa; one from South America; and two from any area to achieve geographic balance.B.IASB GAAP is referred to as International Financi
20、al Reporting Standards (IFRS) and consists of (a) IASs issued by the IASC (and adopted by the IASB), (b) individual International Financial Reporting Standards developed by the IASB, and (c) Interpretations issued by the Standing Interpretations Committee (SIC) (until 2001) and International Financi
21、al Reporting Interpretations Committee (IFRIC).C.In addition to 31 IASs and 13 IFRSs (as of January 2013), the IASB also has a Framework for the Preparation and Presentation of Financial Statements, which serves as a guide to determine the proper accounting in those areas not covered by IFRS.D.As of
22、 June 2012, more than 90 countries required the use of IFRS by all domestic publicly traded companies, and several important countries were to begin using IFRS in the near future. Other countries allow the use of IFRS by domestic companies. Many countries also allow foreign companies that are listed
23、 on their securities markets to use IFRS.E.There are two primary methods used by countries to incorporate IFRS into their financial reporting requirements for listed companies: (1) full adoption of IFRS as issued by the IASB, without any intervening review or approval by a local body, and (2) adopti
24、on of IFRS after some form of national or multinational review and approval process. VI.The U.S. FASB has adopted a strategy of convergence with IASB standards.A.In 2002, the IASB and FASB signed the so-called “Norwalk Agreement” to “use their best efforts to (a) make their existing financial report
25、ing standards fully compatible as soon as is practicable and (b) coordinate their work program to ensure that once achieved, compatibility is maintained.”B.The FASB-IASB convergence process has resulted in changes made to U.S. GAAP, IFRS, or both in a number of areas including: Business combinations
26、, Non-controlling interests, Acquired in-process research costs, Share-based payment, Borrowing costs, Segment reporting, and Presentation of other comprehensive income.C.At the beginning of 2013, the FASB listed joint convergence projects with either an Exposure Draft or final standard expected to
27、be issued in 2013 in the following areas: Leases, Insurance contracts, Financial instruments, Revenue recognition, Investment companies, and Consolidation: Policy and Procedures VII.The U.S. SECs early interest in IFRS stemmed from IOSCOs endorsement of IFRS for cross-listing purposes. A.After consi
28、dering this issue for several years, in 2007 the SEC amended its rules to allow foreign registrants to prepare financial statements in accordance with IFRS without reconciliation to U.S. GAAP. Since 2007, foreign companies using IFRS have been able to list securities on U.S. securities markets witho
29、ut providing any U.S. GAAP information in their annual reports. B.To level the playing field for U.S. companies, in July 2007, the SEC issued a concept release to determine public interest in allowing U.S. companies to choose between IFRS and U.S. GAAP in preparing financial statements. Many comment
30、 letter writers were not in favor of allowing U.S. companies to choose between IFRS and U.S. GAAP instead recommending that U.S. companies be required to use IFRS.C.In November 2008, the SEC issued the so-called “IFRS Roadmap.” The SEC indicated it would monitor several milestones until 2011 at whic
31、h time it decide whether to require U.S. companies to follow IFRS 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.” D.In 2011, the SEC Staff published
32、a discussion paper that suggests an alternative framework for incorporating IFRS into the U.S. financial reporting system. This framework combines the existing FASB-IASB convergence project with the endorsement process followed in many countries and the EU. Some refer to this method as “condorsement
33、.” The framework would retain both U.S. GAAP and the FASB as the U.S. accounting standard setter. At the end of a transition period, a U.S. company following U.S. GAAP also would be able to represent that its financial statements are in compliance with IFRS.E.The 2011 deadline established by the SEC
34、 in its IFRS Roadmap came and went without the Commission making a decision whether to require the use of IFRS in the U.S. In July 2012, the SEC staff issued a Final Staff Report that summarized analysis conducted by the SEC Staff on the possible use of IFRS by U.S. companies, but it did not include
35、 conclusions or recommendation for action by the Commission and did not provide insight into the nature or timetable for next steps. Thus, at the time this book went to press, the SEC had not signaled when it might make a decision about whether and, if so, how IFRS should be incorporated into the U.
36、S. financial reporting system.VIII.IFRS 1, First-time Adoption of IFRS, established guidelines that a company must use in transitioning from previously-used GAAP to IFRS.A.Companies transitioning to IFRS must prepare an opening balance sheet at the “date of transition.” The transition date is the be
37、ginning of the earliest period for which an entity presents full comparative information under IFRS. For example, for a company preparing its first set of financial statements for the calendar year 2017, the date of transition is January 1, 2015.B.An entity must complete the following steps to prepa
38、re the opening IFRS balance sheet:1.Determine applicable IFRS accounting policies based on standards in force on the reporting date.2.Recognize assets and liabilities required to be recognized under IFRS that were not recognized under previous GAAP and derecognize assets and liabilities previously r
39、ecognized that are not allowed to be recognized under IFRS.3.Measure assets and liabilities recognized on the opening balance sheet in accordance with IFRS.4.Reclassify items previously classified in a different manner from what is acceptable under IFRS. IX.IAS 8, “Accounting Policies, Changes in Ac
40、counting Estimates and Errors,” establishes guidelines for determining appropriate IFRS accounting polices.A.Companies must use the following hierarchy to determine accounting polices that will be used in preparing IFRS financial statements. 1.Apply specifically relevant standards (IASs, IFRSs, or I
41、nterpretations) dealing with an accounting issue.2.Refer to other IASB standards dealing with similar or related issues.3.Refer to the definitions, recognition criteria, and measurement concepts in the IASB Framework.4.Consider the most recent pronouncements of other standard-setting bodies that use
42、 a similar conceptual framework, other accounting literature, and accepted industry practice to the extent that these do not conflict with sources in 2. and 3. above.B.Because the FASB and IASB conceptual frameworks are similar, step 4 provides an opportunity for entities to adopt FASB standards in
43、dealing with accounting issues where steps 1 through 3 are not helpful. X.Numerous differences exist between IFRS and U.S. GAAP. A.Differences exist with respect to recognition, measurement, presentation, and disclosure. Exhibit 11.8 lists several key differences.B.IAS 1, “Presentation of Financial
44、Statements,” provides guidance with respect to the purpose of financial statements, components of financial statements, basic principles and assumptions, and the overriding principle of fair presentation. There is no equivalent to IAS 1 in U.S. GAAP.C.The IASB follows a principles-based approach to
45、standard setting, rather than the so-called rules-based approach used by the FASB. The IASB tends to avoid the use of bright line tests and provides a limited amount of implementation guidance in its standards.XI.Even if all countries adopt a similar set of accounting standards, two obstacles remain
46、 in achieving the goal of worldwide comparability of financial statements. A.IFRS must be translated into languages other than English to be usable by non-English speaking preparers of financial statements. It is difficult to translate some words and phrases into other languages without a distortion
47、 of meaning.B.Culture can affect the manner in which an accountant interprets and applies an accounting standard. Differences in culture can lead to differences in application of the same standard across countries. Answer to Discussion Question: Which Accounting Method Really is Appropriate?Students
48、 in the United States often assume that U.S. GAAP is superior and that all reporting issues can (or should) be resolved by following U.S. rules. However, the reporting of research and development costs is a good example of a rule where different approaches can be justified and the U.S. rule might be
49、 nothing more than an easy method to apply. In the United States, all such costs are expensed as incurred because of the difficulty of assessing the future value of these projects. International Financial Reporting Standards require capitalization of development costs when certain criteria are met.T
50、he issue is not whether costs that will have future benefits should be capitalized. Most accountants around the world would recommend capitalizing a cost that leads to future revenues that are in excess of that cost. The real issue is whether criteria can be developed for identifying projects that w
51、ill lead to the recovery of those costs. In the U.S., the FASB felt that such decisions were too subjective and open to manipulation. Conversely, under IFRS, development costs must be recognized as an intangible asset when an enterprise can demonstrate all of the following:the technical feasibility
52、of completing the intangible asset so that it will be available for use or sale;its intention to complete the intangible asset and use or sell it;its ability to use or sell the intangible asset;how the intangible asset will generate probable future economic benefits. Among other things, the enterpri
53、se should demonstrate the existence of a market for the output of the intangible asset or the existence of the intangible asset itself or, if it is to be used internally, the usefulness of the intangible asset;the availability of adequate technical, financial and other resources to complete the deve
54、lopment and to use or sell the intangible asset; and its ability to measure the expenditure attributable to the intangible asset during its development reliably.The IFRS treatment of development costs begs the question: How easy is it for an accountant to determine whether the development project wi
55、ll result in an intangible asset, such as a patent, that will generate future economic benefits?In the U.S., a conservative approach has been taken because of the difficulty of determining whether an asset has been or will be created. To ensure comparability, all companies are required to expense al
56、l R&D costs. As a result, costs related to development costs that prove to be very valuable to a company for years to come are expensed immediately. Do the benefits of consistency and comparability (each company expenses all costs each year) outweigh the cost of producing financial statements that m
57、ight omit valuable assets from the balance sheet? No definitive answer exists for that question. However, the reader of financial statements needs to be aware of the fundamental differences in approach that exist in accounting for development costs before making comparisons between companies from di
58、fferent countries.Answers to Questions1.The five factors most often cited as affecting a countrys accounting system are: (1) legal system, (2) taxation, (3) providers of financing, (4) inflation, and (5) political and economic ties. The legal system is primarily related to how accounting principles
59、are established; code law countries generally having legislated accounting principles and common law countries having principles established by non-legislative means. In some countries, financial statements serve as the basis for taxation and in other countries they do not. In those countries with a
60、 close linkage between accounting and taxation, accounting practice tends to be more conservative so as to reduce the amount of income subject to taxation. Shareholders are a major provider of financing in some countries. As shareholder financing increases in importance, the demand for information m
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