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Deloitte comments on SEC IFRS 'Roadmap'

07 Apr 2009

Deloitte & Touche LLP (United States) has submitted to the US Securities and Exchange Commission its views on the SEC's proposed Roadmap for the Potential Use of Financial Statements Prepared in Accordance with International Financial Reporting Standards by U.S. Issuers.

The letter expresses support for allowing foreign registrants to use IFRSs and for the convergence efforts of the IASB and the FASB. But the letter suggests that there are some areas of the Roadmap that require further consideration by the SEC before it is adopted. Click for:

An excerpt from the Deloitte letter:

We support the steps that the SEC has already taken toward the acceptance of IFRSs in the U.S. capital markets, including allowing foreign private issuers to use IFRSs in their SEC filings without a reconciliation to U.S. GAAP. In our view, IFRSs are of high quality and are sufficiently comprehensive to provide transparent financial information. We also support a standard-setting process that addresses the ongoing needs of financial statement users and makes relevant improvements to standards. To that end, we are supportive of the convergence efforts of the IASB and FASB in developing the highest quality standards.

As with any important policy decision, the Commission will need to consider and weigh various factors in deciding whether to mandate IFRSs for all U.S. issuers. More specifically, the Commission will need to consider recent developments relating to the financial crisis, including the loss in confidence in the U.S. capital markets, the development of capital market alternatives outside the United States, and the impact on global competitiveness. Also, there have been ongoing questions about U.S. financial reporting, including the complexity of U.S. GAAP and the need to have standards that are less reliant on detailed rules and bright lines. While some may argue that, in light of recent events, this is not the time to make fundamental changes in financial reporting requirements, we believe that these very events reinforce the need to rethink the approach to financial reporting.

We support the objective in the proposed roadmap of transitioning all U.S. issuers to IFRSs but have a number of observations and recommendations regarding how the proposed roadmap can be improved. The most important of these recommendations are (1) the current need for the SEC to be more definitive about its plan to transition all U.S. issuers to IFRSs in the future and (2) the removal of the significant disincentives for early adopters of IFRSs.

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Deloitte International Tax Source

07 Apr 2009

The Deloitte International Tax Source (DITS) is likely to be of interest to visitors to IAS Plus – who come from over 200 jurisdictions around the world.

DITS is a comprehensive one-stop web database for international tax rates, information, and analysis key to doing business in a cross-border environment. DITS provides access to:
  • Tax rates for more than 60 jurisdictions, including:
    • Corporate and historical income tax rates,
    • Domestic withholding rates,
    • Withholding tax rates for dividends, interest, and royalties for in-force and pending tax treaties, and
    • Indirect tax rates (VAT/GST/sales tax).
  • Comparative data on holding companies
  • Comparative data on transfer pricing policies
  • An executive library of:
    • International Tax and Business Guides and Highlights
    • A wide range of global tax publications
    • Tax tools
    • Live interactive webcasts led by Deloitte professionals
DITS is free, easy to use, and always available. Access the Deloitte International Tax Source at www.dits.deloitte.com/. There's a short video overview Here to introduce you to DITS.

 

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G20 leaders support global accounting standards

07 Apr 2009

The Communiqué Issued by the Leaders of the Group of 20 (G20) following their meeting in London on 2 April 2009 calls on "the accounting standard setters to work urgently with supervisors and regulators to improve standards on valuation and provisioning and achieve a single set of high-quality global accounting standards".

This recommendation builds on the recommendation in the Final Report of G20 Working Group 1 Enhancing Sound Regulation and Strengthening Transparency (PDF 720k), issued 25 March 2009, which also recommends adoption of a single set of accounting standards globally. The report also recommends greater involvement of representatives of emerging market economies in the IASCF/IASB structure.

Recommendation 23: The IASB should enhance its efforts to facilitate the global convergence towards a single set of high-quality accounting standards by sharing the experience of countries that have completed this process and by providing technical assistance. — Responsibility: IASB — Timeline: Fall 2009 — Monitoring: Expanded FSF

The long-term benefits likely to result from the use of a harmonized set of international accounting standards are considerable, in particular from a market transparency and cost perspective. While adapting IFRS according to national circumstances rather than fully complying with them may be appropriate in some cases to take into account country-specific characteristics of markets, it also voids some of the benefits of a global set of accounting standards.

The Working Group recommends that the IASB facilitate the transition towards a single set of high-quality global standards globally by sharing the experience of countries that have completed this process and by providing global assistance.

Click for Communiqué Issued by the Leaders of the G20 (PDF 174k).

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IFRS insurance accounting newsletter

06 Apr 2009

Deloitte (United Kingdom) has published the second edition of its monthly newsletter focussing on the joint IASB and FASB project to develop a new, comprehensive, global financial reporting standard for insurance.

This issue focuses on the estimate of insurance cash flows. The IASB plans to publish an exposure draft for comment in the second half of 2009 and a final standard in 2011. This newsletter provides an update on progress being made by the IASB and FASB in their joint project. Click to download Issue 2 of the Insurance Accounting Newsletter (PDF 130k). There are permanent links all issues of the newsletter on IAS Plus Insurance Project Page.

 

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11 IFRSs await EU endorsement

06 Apr 2009

The European Financial Reporting Advisory Group (EFRAG) has updated its report showing the status of endorsement, under the EU Accounting Regulation, of each IFRS, including standards, interpretations, and amendments.

Click to download the Endorsement Status Report as of 3 April 2009 (PDF 132k). With the recent endorsement of IFRIC 12 Service Concession Arrangements, there are currently 11 IASB pronouncements awaiting European Commission endorsement for use in Europe, as follows:

Standards

  • IFRS 1 First-time Adoption of IFRS – Restructured standard (2008)
  • IFRS 3 Business Combinations (2008)

Interpretations

  • IFRIC 15 Agreements for the Construction of Real Estate
  • IFRIC 16 Hedges of a Net Investment in a Foreign Operation
  • IFRIC 17 Distributions of Non-cash Assets to Owners
  • IFRIC 18 Transfers of Assets from Customers

Amendments

  • IAS 27 Consolidated and Separate Financial Statements (2008)
  • IAS 39 Amendments for Eligible Hedged Items
  • IAS 39 Amendments for Reclassification of Financial Assets
  • IFRS 7 Amendment – Improving Disclosures About Financial Instruments
  • IFRIC 9 and IAS 39 Amendment – Embedded Derivatives
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Heads Up – SEC's revised financial reporting manual

06 Apr 2009

The Division of Corporation Finance of the US Securities and Exchange Commission released a new version of its Financial Reporting Manual. This 267-page manual is specifically intended for the SEC staff, but because it contains useful information for registrants it has been posted to the SEC's website.

The manual provides the SEC staff's interpretations of form requirements and portions of Regulations S-X and S-K, including guidance on topics such as the form and content of a registrant's financial statements, providing separate financial statements of businesses acquired or to be acquired and investments in entities accounted for by the equity method, pro forma financial information, Management's Discussion and Analysis, and non-GAAP financial measures. Deloitte (United States) has published an updated Heads Up newsletter (PDF 148k) discussing the revised manual. An appendix to Heads Up is a table summarising the more important additions and changes since the previous edition of the manual. Click for:

 

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EU ministers urge IASB to adopt recent FASB fair value decisions

06 Apr 2009

Following their informal meeting in Prague on 3 and 4 April 2009, the EU Finance Ministers and Central Bank Governors (ECOFIN) issued a statement urging the IASB to adopt the conclusions on fair value measurement in illiquid markets and on impairment of financial assets that were approved by the US Financial Accounting Standards Board last week.

Our News Story of 3 April 2009 explains the FASB decisions. Click to Download the ECOFIN Statement (PDF 20k). Here is an excerpt.

The US standard setting authority is in the process of adopting new accounting guidance, with the aim of accurate valuation of assets in illiquid markets which are not functioning properly, which could provide their financial institutions with much more flexibility to move away from using distressed prices in these circumstances. They also propose amendments to current US GAAP impairment rules. These changes could result in a significant divergence of international accounting practice for financial instruments.

Ministers therefore call on the IASB to cooperate closely with the FASB in order to immediately address these issues, with the aim of achieving equivalent treatment and application of parallel standards in the IFRS and US GAAP systems, in order to avoid risks of competitive distortions emerging.

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IFRS checklists in French

06 Apr 2009

Deloitte (Canada) has published French language translations of the 2008 IFRS Presentation and Disclosure Checklist for 2008 and the IFRS Compliance Questionnaire for 2008.

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FEE views on fair value measurement

05 Apr 2009

FEE, the Federation of European Accountants, has submitted its response to the Financial Crisis Advisory Group's 11 March 2009 Invitation to Comment.

With regard to fair value measurement of financial instruments, FEE states:

FEE believes strongly that financial reporting based on IFRS, and notably fair value accounting for financial instruments, has revealed the economic reality of market participants' positions at an earlier stage than otherwise would have been the case under a more cost basis driven model. In our view, the requirement to account for certain financial instruments at fair value has not caused the financial crisis nor has it been a significant contributing factor. Nevertheless, practice has shown that fair value accounting is more difficult to apply in illiquid markets and preparers and auditors have had to use significant judgments to arrive at consistent valuations in difficult market circumstances. Preparers would benefit from additional guidance on fair value measurements when observable market prices are not available.

Financial reporting under IFRS did show that financial institutions were highly geared. The introduction of IFRS 7 further improved risk disclosures on financial instruments. As 2007 was the first year that IFRS 7 was required to be applied and this gave greater scope to risk disclosure, it is expected that risk disclosures will further improve as more experience with the standard is being gained. The Financial Stability Forum disclosure requirements have also enhanced the risk disclosures.

The financial crisis has accelerated the discussion on the need to introduce anti-cyclical measures to the global system of financial regulation and to a certain extent also to financial reporting. Financial reporting has been blamed by some commentators for its pro-cyclical influence, thus aggravating the situation in markets that have become distressed or illiquid. We are of the opinion that the effects of the current market volatility are captured, but not caused by fair value accounting. Fair value provides a timely and relatively objective measure of existing value. Failure to report such values would leave investors and policy decision makers less aware or even unaware of credit and liquidity challenges. The accounting policies need to indicate carefully on which basis the fair values concerned have been determined.

Click to download the FEE Response to FCAG (PDF 84k)

 

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Notes from the IASC Foundation Trustees meeting

03 Apr 2009

The Trustees of the IASC Foundation, under which the IASB operates, met in London on 1 and 2 April 2009. Presented below are the preliminary and unofficial notes taken by Deloitte observers at the public portion of the meeting.

The Trustees also held a joint meeting with the new IASCF Monitoring Board on 1 April. Our notes of that meeting are posted separately immediately below.

Notes from the Meeting of the IASC Foundation Trustees - 1 and 2 April 2009

Review of the IASB Work Programme: Progress on Issues Raised by the G20 and Financial Stability Forum

The IASB Chairman reviewed with the Trustees the work of the Board to answer the demands of the G20 and Financial Stability Forum. He outlined that the IASB would work to replace IAS 39 in 'months not years' (perhaps 6-8 months) and was already working closely with the FASB and prudential regulators.

There was broad support from the Trustees on the IASB's intended actions, although some thought that the IASB was being too defensive. In particular, some of the IASB's proposed actions could be seen as radical. What was important was to maintain the commitment to high quality global standards: no more quick fixes.

An underlying concern, and one perhaps for the Monitoring Board to consider, was what would happen if the FASB 'went left' and the IASB 'went right'? International convergence was still the goal, but the two main standard-setters were subject to tremendous pressure in their own markets.

A Trustee noted that 'dynamic provisioning' was an unfortunate term and one that lacked an agreed definition. Were he a Board member, he would not support any loan loss model that allowed for cookie jar reserves. However an approach that allowed for a thoughtful way to provide for losses in the financial statements, that was transparent, and that allowed the possibility of expected losses 'might be a great place to be'.

Sir David thanked the Trustees and noted that the staff was already hard at work on the issue.

Report of the Due Process Oversight Committee

The Trustees received a report from the chairman of the Trustees' Due Process Oversight Committee. The committee will include a summary report in the IASC Foundation's annual report and include a more comprehensive report on its activities on the Foundation's website.

The focus of the committee in 2008 would be, in particular, the standard-setting process at the IASB; and the effectiveness of working groups.

The draft report of the Committee for inclusion in the IASCF's Annual Report was approved.

The Trustees also agreed to issue a Due Process Handbook for the IASCF's XBRL Activities, which will be released in early April for a 90-day public comment period. There was some discussion of the quality assurance (especially 'accounting technical') processes around the IFRS XBRL Taxonomy, especially the extent to which it interprets IFRSs into the financial statements in a particular way, and that technical accounting experts are satisfied that that application is appropriate. This point will receive particular attention of the quality review teams and a report will be made to the July Trustees' meeting.

Trustee Robert Glauber reported on his impressions of the reconstituted Standards Advisory Council. He noted that the SAC wants feedback from the IASB that addresses their comments on the agenda and other issues discussed with it. Trustees noted that, to be truly effective, the SAC needed to be used properly, and to be respected.

Report on the Constitution Review

The IASCF staff presented a draft of the proposed Feedback Statement on Phase I of the Constitution Review. There was no substantive discussion of this document.

The staff noted that the comment period on the opening round of Phase 2 of the review had closed on 31 March. The staff would be analysing the comments and discussing them with the Constitution Committee before bringing recommendations for changes to the Constitution to the July 2009 Trustees' meeting. The review must be completed by 2010. It was intended to hold public roundtables in Asia (Tokyo), the Americas (New York), and London, late in 3Q and during 4Q 2009.

The staff also noted that the Monitoring Board's Charter would be published on 2 April 2009. The staff noted that the Charter required decisions by consensus and that any change to that would probably need Trustee concurrence, even though the Trustees are not a signatory to the Charter (they are a signatory to the Memorandum of Understanding).

IFRS Dissemination Strategy

Sir Bryan Nicholson, chair of the Finance Committee, presented various approaches to implementing the decision made in October 2008 to provide free access to the mandatory elements of IFRSs. The approaches outlined the key issues to be addressed if the IASCF were to provide more of its materials for free.

The decision was closely related to the long-term funding arrangements for the organisation. In 2008, the IASCF recorded a profit of £3.3 million on the sale of publications and related activities, such as licensing the content to others. This is part of the IASCF's overall funding base.

The Trustees noted that, until the stable funding system is in place and fully operational, they probably could not afford to lose significant revenue streams. Therefore, they agreed not to extend free access to non-mandatory elements of IFRS and other materials for the moment. They committed to reconsidering this position in 2011, by which time they will be able to assess the effect of providing free access to the mandatory content.

XBRL Developments

Olivier Servais, the IASCF XBRL Team Leader, presented an overview of developments with respect to the IFRS XBRL Taxonomy. The Trustees approved the 2009 XBRL Taxonomy for issue and it is now public.

The Trustees approved the draft XBRL Due Process Handbook for exposure and this was released on 2 April 2009 for a 90-day comment period.

The XBRL staff also reviewed budgets and other matters, but there was little discussion of these items.

There was more discussion of whether the IASCF should develop 'IFRS Taxonomy Extensions' – additional tags that go beyond the mandatory IFRS requirements (for instance, to disaggregate property, plant and equipment, or address industry-specific line items).

The staff presented a proposal under which they would work with the IASB and the Trustees Due Process Oversight Committee to develop an approach to the issue. This would be presented at the July 2009 Trustees' meeting.

In discussing the proposals, the Trustees were very aware of the delicate balance that they had to achieve: was XBRL a business tool or an official pronouncement? How was it to be branded? In addition, by exploring 'taxonomy extensions', the XBRL was taking the IASB into industry-specific areas – something that the IASB has consistently resisted doing.

Trustees cautioned that care was needed in deciding what to do and how far to go. This needed to balance the desires of securities regulators to have common extensions against concerns about unintended interpretations of IFRSs. This suggested that a shared responsibility approach was most desirable.

The IASCF staff noted that they were already working with IOSCO and others to explore how to make such co-operation operational.

Review of Long-term Funding of the IASC Foundation

The Trustees discussed progress towards a stable long-term funding regime for the IASCF. They noted that if they were to expand their activities to the budgeted £23 million level as planned, the IASCF would face a £6.6 million funding gap (about £4 million if you include publication revenues in the contribution line).

The Trustees discussed the implications of this at some length. One Trustee noted that, with the agreed central funding in the European Union from 2011, there was no certainty that voluntary funding would continue (it would likely not continue in some Member States at least). It was noted that the 'programme funding' did not include the US$8 million contributed by the major accounting networks on an annual basis. Sam DiPiazza noted that the networks were not asking to be relieved of this contribution, but did acknowledge that the networks' contribution impairs the independence of the IASCF.

Sir Bryan Nicholson noted that IFAC's Public Interest Oversight Board takes a very close interest in the allocation of public funds. It is likely that the IASCF's Monitoring Board will do likewise: therefore it is necessary that the Trustees are realistic about raising money. The jump to the long-term funding regime cannot be accomplished in one year. The IASCF will continue to have a mixture of voluntary contributions and programme funding for a while longer, and will need the net proceeds of the sale of publications as well.

The Trustees' finance committee will meet in the near future and will return with further proposals at the July 2009 meeting.

This summary is based on notes taken by observers at the IASCF Trustees meeting and should not be regarded as an official or final summary.

 

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