| TAX AND ACCOUNTING/ BUDGETING |
June 2002 |
ON THE SAME PAGE
US and international standard setters
are coordinating their efforts to craft a common language
for business.
By Tim Reason
Comparing international accounting standards
(IAS) and US generally accepted accounting principles (GAAP)
brings to mind the old lyric about toma-toes and to-mah-toes.
On paper they look almost the same, thanks to diligent efforts
by standard setters to eliminate the practical differences
between them. But start applying them with different international
accents, and suddenly you can understand why some people want
to call the whole thing off.
That's not likely to happen, however.
The convergence of IAS and GAAP continues apace. Robert Hertz,
the new chairman of the US Financial Accounting Standards
Board (FASB), who will take over on July 1 from outgoing chairman
Ed Jenkins, is an American representative to the London-based
International Accounting Standards Board (IASB) who is not
shy about criticizing certain aspects of GAAP. Meanwhile,
the FASB and the IASB are already working in concert. "When
[the IASB] puts projects on its agenda, we will try to put
them on our agenda," says Carrie Bloomer, FASB international
project manager.
That means FASB is now caught up in the
IASB's race to revamp IAS. In March, the European Parliament
ruled that the consolidated financial statements of all companies
with public shares listed in the European market - some 7,000
companies currently using their home country's GAAP - must
follow IAS standards no later than December 31, 2005. In Asia,
countries such as Hong Kong, China and Singapore are also
moving toward the IAS standard, although few fixed dates have
been set for implementation.
Currently, the US Securities and Exchange
Commission (SEC) does not accept IAS; the roughly 50 foreign
private issuers in the US that use it are required to reconcile
their financial statements with US GAAP. Their ranks will
swell to between 500 and 600 as European companies convert
from their home-country standards to IAS, estimates DJ Gannon,
partner at US-based accountants Deloitte & Touche. This tenfold
increase, coupled with the SEC's burdensome reconciliation
requirement, "puts pressure on the standard setters to get
their act together," declares James Leisenring, an IASB board
member and a former FASB director.
You Say Principles, I Say Rules
Ultimately, getting their act together
means eliminating the remaining significant differences between
the two sets of standards. That task is complicated by cultural
and political issues, such as the debate over FASB's "rules-based"
approach versus the "principles-based" approach of the IASB.
Believers in the superiority of US GAAP claim that IAS leaves
far too much to interpretation, while defenders of IAS note
that FASB's voluminous guidance didn't prevent Enron from
parsing accounting rules to a fault.
FASB's new chairman appears sympathetic
to that view. "There is all this debate over whether Enron
violated the 3 percent rule," scoffs Herz, referring to the
level of outside investment required to legally define Enron's
partnerships as independent. In Europe, where control and
recourse aren't defined by quantitative thresholds, he says
the reaction is: "That's a nonsense rule to begin with."
Indeed, last March, SEC commissioner Harvey
Pitt gave principles-based standards a plug while testifying
before Congress about Enron. The SEC plans to use its statutory
authority, said Pitt, to ensure "that FASB's standards evolve
to become general principle-based standards instead of overly
complex, rule-based standards."
Knotty Issues
Variation in enforcement is also a source
of controversy. "Part of the reason you can't be sure you
have eliminated the differences between standards is that
we don't have an SEC in the rest of the world," observes Leisenring.
"How do we know what people are really doing when they apply
the standards?" he asks.
Even examining the SEC filings of the
50 or so US foreign issuers that currently reconcile their
IAS financial statements with US GAAP doesn't provide a good
gauge of the most common differences, says Lisenring. "Anybody
that knew they were filing in the US would make elections
[under IAS] to get as close to US GAAP as they could," he
explains. "If there were no reconciliation requirement, they
wouldn't necessarily make the same elections," he says.
In some cases, eliminating the differences
between GAAP and IAS will result in replacing existing standards
with completely new ones. FASB and the IASB "are focused on
quality as an output as opposed to just convergence," says
FASB's Bloomer. There will clearly be cases where an existing
FASB or IASB standard is selected as superior. "But that's
not going to happen as often as we will say, 'Track A and
track B are not compatible, they are not reconcilable, so
let's go down track C,'" says Leisenring.
For example, both standards allow smoothing
to determine the value of pension assets - a technique that
resulted in many companies showing substantial paper gains
despite the bear market. But deciding which standard's calculation
method is best may be a Gordian knot that is easier to simply
cut. "Most of the world has some kind of smoothing mechanism,
but they are all different," comments Herz. "So the basic
question is, do you keep those smoothing methods or not? Is
it better just to show the assets at fair value?" he asks.
In the US, CFOs have been preparing for
possible changes to GAAP for some time. Back in December 2000,
a survey of Financial Executives International members ranked
preparing for such changes as number two in the top ten challenges
facing them for 2001. A recession and terrorist attacks changed
a lot of priorities last year, but the issues haven't gone
away.
Indeed, serious wrangling has already
begun over stock options, which the IASB says should be expensed.
FASB said the same thing in 1993 while drafting FAS 123, but
in its final standard it bowed to fierce opposition from businesses
and politicians. "FAS 123 is abundantly clear that the, quote-unquote,
compromise of footnote disclosure was not what the board perceived
to be the best answer," says Bloomer.
If the IASB withstands the new howls of
protest already coming from US companies, it could lend FASB
the additional clout it needs to revise FAS 123. "If we can
say that we have considered the thinking of standard setters
around the world it might help support a new standard even
if it was unpopular," declares Bloomer.
Top of the Agenda
Other high-profile issues have already
been handled with remarkable dispatch. Despite some objections
from the business community, FASB eliminated pooling-of-interests
accounting for acquisitions in 2001; the IASB plans to do
the same this year. "Business combinations look to be a big
deal because they are usually big transactions," states Leisenring.
"But the [differences] that are probably more important are
pervasive and repeat themselves, like [accounting for] pensions
and foreign currency."
At the top of the IASB's current agenda
is the Improvements Project, a potpourri of changes to 14
existing standards. Some items, such as accounting for foreign
exchange and investments in unconsolidated subsidiaries, align
international standards more closely with US GAAP, says Leisenring,
but "about half of them move the other way." Among the most
dramatic divergence is the elimination of LIFO (last-in, first-out).
"I don't think anybody thinks LIFO is a good inventory method
for anything except tax purposes," he says.
The Improvements Project also eliminated
extraordinary items. "That will look like a bigger difference
than it is," explains Leisenring, "because there aren't that
many extraordinary items anyway." In the US, reporting of
extraordinary items has become a fairly ordinary occurrence.
While not eliminating the category, says Bloomer, FASB has
decided to rescind one of the primary sources of extraordinary
items - the early extinguishment of debt. "When FAS 4 was
issued, that was an extraordinary item," she notes. "Now,
because of all kinds of innovations in the financial market,
companies are more flexible in their ability to retire debt,"
she says.
Indeed, says Bloomer, it is those
types of innovations - as much as the need for global standards
- that have IASB and FASB rewriting accounting standards.
"We need to remember that standard setting isn't static,"
she says. Or predictable. As the standard setters start wrestling
with thorny issues such as accounting for stock options, goodness
knows what the end will be.
Tim Reason is a staff writer at CFO
in the US, CFO Asia's sister publication.
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