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U.S. comment letter on cloud computing arrangement fees

Published on: Nov 19, 2014

Deloitte & Touche LLP comments on the proposed Accounting Standards Update, Customer's Accounting for Fees Paid in a Cloud Computing Arrangement, issued by the FASB on August 20, 2014.

An excerpt from the comment letter is shown below:

We support the Board’s efforts to quickly make improvements to areas of U.S. GAAP that are unnecessarily complex and costly as part of its simplification initiative. With respect to a customer’s accounting for a cloud computing arrangement, we agree with the proposed criteria for distinguishing a service contract from the purchase of a license. However, as noted in our responses to the proposed ASU’s questions for respondents (see appendix below), we believe that the Board could further simplify and clarify certain aspects of this project without dramatically increasing its scope.

Full text of the comment letter is available below.

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