Bringing International Accounting Issues into the Classroom Isabel

Bringing International Accounting Issues into the Classroom Isabel Wang Associate professor Department of Accounting & Information Systems Broad School of Business Michigan State University

Why Care? Friedman (2005): the world is flat. However, accounting is still diverse.

Environmental Factors Leading to Accounting Diversity Inflation Some countries have historically high rates of inflation. This is common in Latin American countries. Given extended periods of low inflation in the U.S., inflation accounting is not required. Political and economic ties These linkages tend to make information sharing easier. Nations that share ties often have similar accounting systems, such as France and former colonies in western Africa.

Environmental Factors Leading to Accounting Diversity Taxation U.S.--taxable income and book income are generally quite different. Germany--rules governing taxable and book income tend to be the same, which generally results in more conservative accounting. Deferred taxes are less of an issue in code law countries. Providers of financing In many countries major sources of capital are families, banks, and the government. Accounting and disclosure in those countries tend to be less important. But accounting and disclosure are more important where providers of financing are diverse shareholders (e.g, U.S. and U.K.).

Environmental Factors Leading to Accounting Diversity Legal systems --Common law Has relatively fewer statutes and more interpretation by courts to apply laws to specific situations Leads to the creation of precedents or case law Found most often in Great Britain and other English-speaking countries The source of accounting rules tends to be non-governmental organizations. Legal systems --Code law Characterized by relatively more statutes Found more often in non English-speaking countries Accounting rules in these countries tend to be legislated (i.e., the source is the government). Less specific, so other sources needed to provide guidance

Dealing with Accounting Diversity Form 20-F Required by the SEC for companies using non-U.S. GAAP Reconciles net income and stockholders’ equity from the other GAAP to U.S. GAAP Compliance Week (2007): Denis Duverne, chief financial officer of AXA Group, estimated that his company would save 25 million if the reconciliation requirement is dropped. William Widdowson, head of group accounting policy at UBS, said the reconciliation adds 30 pages to the Swiss bank’s filing, contributing to the problem of “information overload.”

What Do Cross-listed Firms Choose? - Jiang, Petroni, Wang (2010) Year 2008 Year 2007 IFRS LOCAL GAAP US GAAP Total Total IFRS LOCAL GAAP US GAAP 88 1 0 89 5 147 9 161 5 1 237 243 98 149 246 493

A Tale of Two Boards – a long march 2002 .09 Norw alk Agre eme nt 200 8.09 FAS B/ IASB road map upd ate 2006 .02 FASB /IASB Road map 200 9.0 4 Sch apir o’s Vie w 2010.04 SEC staff work plan 2011. 05 SEC alternative approach: condorsement 200 8.08 SEC Roa dma p 2009 .11 FASB reaffi rmed com mitm ent 2010.08 FASB Chairman resignation 2012. 07 SEC Final Staff Report 2011.04 FASB progress report 2013. 04 SEC new chairman Mary Jo White

Key Events 09/18/2002: The Norwalk Agreement commitment to develop “high quality, compatible accounting standards that could be used for both domestic and cross-border financial reporting.” 2/27/2006: FASB/IASB Roadmap MoU: by 2008 reach a conclusion about whether major differences should be eliminated in a few focused area; make significant progress on joint projects needing improvement In 2007 the SEC removed the reconciliation requirement for nonU.S. companies that are registered in the United States and use IFRSs as issued by the IASB. 08/27/2008: SEC Roadmap Set forth seven milestones that, if achieved, could lead to mandatory adoption of IFRS by US issuers in 2014. Determine whether to proceed with the above timeline in 2011

SEC’s Proposed Road Map Issued Nov 2008 By 2014 may see IFRS required in US Early use permitted in 2010 For large firms in industries where IFRS is predominant Decide in 2010 whether 2014 will be deadline Comments were due Feb 2009 Status: Fall 2009: SEC draft strategic plan proposes to promote ongoing convergence “where appropriate” between the FASB and IASB Goal of significant convergence by end of 2011.

Key Events 09/2008: Update to FASB/IASB Roadmap Short-term convergence projects completed: Fair value option, R&D for FASB; borrowing costs and segment reporting for IASB 4/07/2009: Chairman Schapiro’s view CFO.com "I will not be bound by the existing roadmap that's out for public comment," and expressing reservations about quality of IFRS and the independence of the International Accounting Standards Board, which writes those rules.” 11/05/2009: FASB Reaffirm Commitment Discuss plans for completing major joint projects by the end of June 2011. 04/2010: SEC staff work plan No early adoption Schapiro stressed that the commission is “on track to make a recommendation in 2011,” but mandatory IFRS adoption is a highly significant decision that would be made only if it is certain that it is the best move for investors and the companies involved

Key Events 8/24/2010: FASB chairman Herz unexpected resignation 4/21/2011: FASB progress report Reaffirm commitment to convergence As of November 2010, priority projects include our joint projects on financial instruments, revenue recognition, leasing, insurance contracts, the presentation of other comprehensive income, fair value measurement, and the consolidation of investment companies As of April 2011, the number of remaining priority MoU projects is reduced to three (revenue recognition, leasing and financial instruments). Extended the timetable for the remaining priority MoU convergence projects and insurance beyond June 2011 to permit further work and consultation with stakeholders.

Recent Development May 26, 2011: SEC outlines “an alternative way of merging U.S. and international accounting standards that could keep down transition costs, especially for small issuers.” (Reuters, May 26, 2011) July 13, 2012: SEC Final Staff Report – no recommendation; chief accountant resigned April 8, 2013: Mary Jo White as new SEC chairman – IFRS decision on her to-do list What do we do? Wait-and-see

External Political EnvironmentFinancial Accounting Canada 2009*/2011 United States 2015 ? Japan 2010*/2016 ? China 2007 India 2011 Mexico 2012 Adopted or will adopt Developing plans to adopt Brazil 2010 Australia 2005 No plans or unknown Argentina 2012 South Africa 2005

Adoption of IFRS Over 12,000 companies in about 120 nations European Union Required to use IFRS since 2005 9,000 companies 400 trade on US markets Switched to IFRS Australia, New Zealand, South Africa, Singapore, Hong Kong, Philippines, Korea, Canada Stopped creating their own GAAP and use some form of IFRS Croatia, Costa Rica, Cyprus, Dominican Republic, Ecuador, Guatemala, Haiti, Honduras, Jamaica, Kenya, Malta, Mauritius, Napa, Oman, Panama, Tanzania, Tajikistan, Trinidad, and United Arab Emirates Planned switch to IFRS India, Japan Delayed adoption – India (postponed to April 2012) http://www.pwc.com/us/en/issues/ifrs-reporting/publications/ifrs-status-country.jhtml

IFRS Adoption vs. Convergence Canada, Australia – have adopted, but China – has converged, but allows pooling and purchase methods India – IFRS optional, over 60 carveouts U.S. – Herz: no convergence for 1015 years (CFO.com, April 20, 2009)

IFRS-US GAAP Major Differences - Inventory IFRS Lower of cost or net realizable value (NRV); LIFO - prohibited; Write-down reversible - allowed US GAAP Lower of cost or market; LIFO - allowed; Write-down reversible - prohibited

IFRS-US GAAP Major Differences – PP&E IFRS Cost model (same as GAAP) Revaluation model (fair value based; entire class of assets) US GAAP Only cost model allowed

IFRS-US GAAP Major Differences – Intangible Assets IFRS Purchased: cost model & revaluation model Internally generated R– research expenditures (expense), D- development expenditures (capitalize/deferred); If can’t distinguish the two, expense. US GAAP Purchased: cost model Internally generated: expense all

IFRS-US GAAP Major Differences – Impairment IFRS – one step impaired when carrying value (book value) exceeds recoverable amount. Recoverable amount the greater of net selling price and value in use Impairment loss reversible, but not to exceed what it would have been if no impairment loss had been recognized. US GAAP – two step approach Step 1: Recoverability test (undiscounted future cash flows) Step 2: Impairment loss C.V. – fair value Impairment loss: not reversible if held for use, reversible if held for sale

IFRS-US GAAP Major Differences – Borrowing Costs IFRS - two alternatives Expense all borrowing cost in the period incurred (eliminated due to convergence) Capitalize to the extent they’re attributable to acquisition, construction, or production of qualifying assets; expense other borrowing costs US GAAP Capitalization of borrowing costs directly attributable to acquisition, construction, or production of qualifying assets

Where to Get More Information Books Introductory - International Accounting and Multinational Enterprises, 6th Edition by L. Radebaugh, S. J. Gray, & E. Black; OR IFRS primer: International GAAP basics, U.S. edition by I. Wiecek & N. Young Integrated entry level - Financial and Managerial Accounting: The Basis for Business Decisions 16th Edition OR Financial Accounting 15th Edition, by Williams, Haka, Bettner, & Carcello, McGraw-Hill/Irwin, 2012 Upper level financial - International Accounting, 3rd edition by T. Doupnik & H. Perera, McGraw-Hill Irwin, 2011 OR International Accounting, 7th edition, by F. Choi & G. Meeks, Pearson, 2010

Where to Get More Information Journals - International The International Journal of Accounting Advances in International Accounting Journal of International Business Studies Journals - AAA Journal of International Accounting Research Accounting Horizons Issues in Accounting Education Other Management Accounting Journal of Accountancy Economist

Where to Get More Information- AAACommons

Where to Get More Information- websites Firms with web based IFRS materials: KPMG: www.kpmginstitutes.com/ifrs-institute/ Ernst & Young: a private password protected website at www.ey.com/us/ifrs. To request an account, please contact the EY ARC Program Director, Catherine Banks, at [email protected]. PWC: IFRS Ready www.pwc.com/extweb/aboutus.nsf/docid/70CCD8B601397905852574910075A03D www.pwc.com/en US/us/issues/ifrs-reporting/publications/assets/pwc-ifrs-by-country-apr-2 012.pdf Deloitte: www.iasplus.com/index.htm; IFRS University Consortium http://www.deloitte.com/us/ifrs/consortium; Table about use (adoption or convergence or ) of IFRS by Jurisdiction: www.iasplus.com/country/useias.htm Other FASB: www.fasb.org/jsp/FASB/Page/SectionPage&cid 1176156245663 IASB: www.ifrs.org/Use around the world/Use around the world.htm AICPA: www.aicpa.org/BecomeACPA/CPAExam/ForCandidates/FAQ/Pages/IFRS FAQs.aspx IAAER: www.iaaer.org/resources/

Where to Get More Information Case Books International Accounting: A Case Approach edited by Schweikart, Gray and Roberts, McGraw-Hill Cases- Journals Issues in Accounting Education: (e.g., Nov. 2007, vol. 22, no. 4) Cases - websites http:// www.ifrs.com/overview/financial listing.html(AICPA) Accounting firms’ websites [email protected] [email protected]