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U.S. comment letter on identifiable intangible assets

Published on: Aug 23, 2013

An excerpt from the comment letter is shown below:

[W]e believe that any final decisions made regarding this proposed ASU should not precede the finalization and issuance of the Private Company Decision-Making Framework — A Guide for Evaluating Financial Accounting and Reporting Guidance for Private Companies (“Decision Framework”).

[W]e find it interesting that the first three amendments proposed by the Board and PCC would result in differences pertaining to recognition and measurement. We believe that the Basis for Conclusions should clearly articulate why such recognition and measurement differences are justified; such justification should extensively take into account various users’ needs and not just primarily focus on reduced cost and complexity.

If the Board and PCC confirm that the benefits associated with separate recognition of identifiable intangible assets that only meet the separability criterion and measurement of these assets at fair value do not provide significant information to private-company financial statement users, we would not object to subsuming intangible assets that only meet the separability criterion into goodwill.

[W]e disagree with not factoring market-participant expectations about the potential renewals or cancellations into the recognition and measurement of contractual intangible assets.

Full text of the comment letter is available below.

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