Two Special Reports from Deloitte & Touche (USA)

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27 Jan 2008

Deloitte & Touche LLP (United States) has published two Special Reports – available via the links below (and on our United States Page).

These new publications offer insight into the comments by the staff of the US Securities and Exchange Commission on the financial statements of domestic registrants and foreign registrants using IFRSs. These are the first two reports in a planned series.


SEC Comment Letters on Domestic Registrants: A Closer Look (PDF 555k): This Special Report presents examples of the most frequently issued SEC comments. The topics covered in this report include:

  • Business combinations, long-lived assets and impairments
  • Contingencies
  • Discontinued operations and assets held for sale
  • Earnings per share
  • Fair value and the turmoil surrounding the credit market
  • Financial instruments
  • Financial statement classification
  • Management's discussion and analysis
  • Revenue recognition
  • Staff Accounting Bulletin 74
  • SEC reporting (Regulation S-X misapplication)
  • Segment reporting
  • Share-based payments
  • Uncertain tax positions
  • Use of experts and consents


SEC Comment Letters on Foreign Private Issuers Using IFRSs: A Closer Look (PDF 555k). This Special Report is designed to help financial statement preparers understand the items that the SEC staff has focused on during its review process over the past two years. It includes extracts from actual comment letters as well as forward-looking considerations. The main topics covered in the IFRS report include:

  • Financial instruments
  • Income statement presentation
  • Revenue
  • Cash flow statements
  • First-time adoption of IFRS
  • Segment reporting
  • Income taxes
  • Employee benefits
  • Impairment of assets
  • Provisions

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