International Accounting Harmonization Where in the World are We Now?

Transcription

1 37th Annual Accounting Conference October 24, 2013 Eccles Conference Center, Utah State University International Accounting Harmonization Where in the World are We Now? Presented by Marc A. Gardiner CPA Chief Executive Officer, IASeminars Ltd.

2 About the Speaker Marc A. Gardiner CPA is Chief Executive Officer of IASeminars, a financial training company based in London which specializes in international accounting seminars around the world. Over the last 10 years, some 15,000 participants have come from some 140 different countries to attend events on 5 continents that were designed, organized and delivered by IASeminars. Marc specializes in seminars on IFRS and US GAAP, and also reporting to the international capital markets. After graduating from the London School of Economics, he worked in public accounting and academia before founding IASeminars. Marc is a Certified Public Accountant and has lived and worked in the UK, France, the USA and Switzerland. 2

3 Presentation Summary Global accounting convergence / harmonization the story so far The use of IFRS around the world, and the current US position The pros and cons what s wrong with US GAAP anyway? Conclusion is it going to happen and, if so, when? 3

4 Global Accounting the Story So Far International Financial Reporting Standards (IFRS) are issued by the International Accounting Standards Board (IASB) and differ in certain important respects from U.S. Generally Accepted Accounting Principles (GAAP) The IASB ( is an independent accounting standard-setting body, based in London. Consists of 16 board members from multiple countries (including 4 from the U.S.) Funded by contributions from major accounting firms, private financial institutions, industrial companies, central and development banks, etc. The Securities and Exchange Commission (SEC) has consistently supported convergence of global accounting standards. However, the Commission has not yet decided whether to incorporate IFRS into the U.S. financial reporting system 4

5 Global Accounting the Story So Far 1973: International Accounting Standards Committee (IASC) formed 1973: FASB formed = a private-sector independent body that establishes and interprets U.S. GAAP and is recognized by the SEC 2001: International Accounting Standards Board (IASB) replaces IASC 2002: SEC announces its support for the Norwalk Agreement between the FASB and the IASB relating to improvement and convergence of accounting standards 2008: SEC abolishes requirement for foreign private issuers to reconcile to U.S. GAAP - provided that their financial statements fully comply with IFRS 2011: IFRS questions included in the Uniform CPA Exam. AICPA launches its IFRS Certificate 2012: SEC staff issued a final report on IFRS adoption without making a recommendation. Since then.. not much has happened! 5

6 Use of IFRS Around the World 2009: Leaders of the Group of 20 major countries (G20) issued a statement calling for the convergence of accounting standards in member nations by 2011 More than 120 nations and reporting jurisdictions currently permit or require the use of IFRS for domestic listed companies European Union (28 countries) requires companies whose securities are listed on an EU-regulated stock exchange to prepare consolidated financial statements using IFRS Australia, New Zealand and Israel have essentially adopted IFRS as national standards Brazil started using IFRS in 2010 Canada adopted IFRS in 2011 Mexico and Nigeria adopted IFRS for all listed entities starting in : Japan and China are working to converge their standards with IFRS Many other countries have plans to adopt IFRS or to converge their national standards with IFRS (e.g. Colombia, India) For more info, see FASB, IASB and SEC websites plus AICPA's IFRS resources website ( 6

7 The SEC s Stance = legal / regulatory Since 1934, the Securities and Exchange Commission (SEC) has had statutory authority to establish financial accounting and reporting standards for publicly held companies. Throughout its history, however, the Commission s policy has been to rely on the private sector for this function For the past three decades, the SEC has been vocal in its support for a single set of robust accounting standards that would be used worldwide SEC statement in 2000: With the activities and interests of investors, lenders and companies becoming increasingly global the only way to achieve fair, liquid and efficient capital markets worldwide is by providing investors with information that is comparable, transparent and reliable. That is why we have pursued a dual objective of upholding the quality of financial reporting domestically, while encouraging convergence towards a high quality global financial reporting framework internationally 7

8 The SEC s Stance = legal / regulatory 2008: SEC issued a proposed Roadmap that, if adopted, could result in the mandatory use of IFRS by U.S. SEC registrants 2010: SEC initiated a Work Plan to enable it to make a decision on whether, when, and how IFRS might be incorporated into the U.S. financial reporting system In 2011, assuming completion of the convergence projects and the SEC staff s work plan, the SEC will decide whether to incorporate IFRS into the U.S. financial reporting system for U.S. issuers and, if so, when and how. If the SEC determines to incorporate IFRS into the U.S. financial reporting system the first time U.S. entities would be required to report under such a system would be no earlier than This timeline will be further evaluated as part of the Work Plan Since then timescales have slipped and SEC enthusiasm has dimmed 8

9 The SEC s Stance = legal / regulatory 2012: SEC issued a Staff Report describing the positive and negative aspects of IFRS, but did not provide a recommendation on how the US should proceed Staff report did not address whether U.S. public companies should have the option to adopt IFRS on a voluntary basis, but did state that investors are generally in agreement that companies should not be permitted to adopt IFRS early, because it would compromise comparability with U.S. companies applying U.S. GAAP SEC staff examined a number of unresolved issues relating to the potential incorporation of IFRS into the U.S. financial reporting system. These issues included, among others, the diversity in how IFRS are interpreted, applied and enforced in various jurisdictions around the world; the potential cost to U.S. issuers of adopting or incorporating IFRS; investor education; and governance No indication since then as to whether, or when, the SEC will progress the IFRS issue 9

10 Relevance of IFRS in U.S. U.S. business is affected by IFRS in multiple ways: Competitiveness of the U.S. capital markets (regulatory burden) U.S. GAAP continues to be influenced by IFRS Cross-border M&A and capital-raising frequently require use of IFRS; Non-U.S. stakeholders in U.S. companies may prefer the use of IFRS; Foreign subsidiaries of U.S. multinationals may need to comply locally with IFRS Corporate oversight of non-us subsidiaries' IFRS accounting Potential international tax implications Investor perspective - the need to understand IFRS is arguably even greater. Over $6 trillion of U.S. capital is invested in foreign securities U.S. markets are already open to non-u.s. companies that prepare their financial statements using IFRS There are over 450 foreign filers with a combined market capitalization in the billions of U.S. dollars who publish IFRS figures without any reconciliation to U.S. GAAP 10

11 IFRS / US GAAP Convergence Initial efforts focused on harmonization reducing technical differences among the accounting principles used in major capital markets around the world. Later the notion of harmonization was replaced by the concept of convergence the development of a unified set of high-quality, international accounting standards Convergence has been a high priority on both the FASB and IASB agendas since 2002 Meanwhile, both sets of standards are more alike than different Conceptual frameworks are similar for both, leading to similar accounting results for most transactions Material differences can nonetheless arise depending on a variety of factors Most of the major accounting firms publish regular studies of the outstanding technical differences between IFRS and US GAAP 11

12 The FASB s Stance FASB and IASB have worked towards improvement and convergence of accounting standards since they signed the Norwalk Agreement in 2002 shared goal of developing compatible, high-quality accounting standards that could be used for both domestic and cross-border financial reporting established broad tactics to develop standards jointly, eliminate narrow differences whenever possible, and, once converged, stay converged Memorandum of Understanding issued in 2006, updated in 2008 and 2010 Juggling act Unless and until a decision is made to adopt IFRS in the U.S., or until we have achieved substantial convergence between U.S. GAAP and IFRS, the FASB will need to continuously manage the challenging task of balancing the demand for improved U.S GAAP with the desire to eliminate differences between it and IFRS 12

13 Convergence So Far The Boards have completed several converged accounting standards, including business combinations, non-controlling interests, and fair value measurement These standards were then issued as both U.S. GAAP and IFRS FASB and IASB missed a June 2011 deadline for completing four other key convergence projects due to resource constraints and technical disagreements Revenue recognition, financial instruments, leases and insurance - still in progress FASB priority is to complete these convergence projects Final standards expected in 2014 on revenue recognition, on financial instruments and on leases The standard on insurance contracts is not expected before 2015 Biggest difference is still that IFRS provides fewer detailed rules than U.S. GAAP IFRS also contains limited industry-specific guidance. 13

14 Convergence - Next Steps 2013: Norwalk Agreement formally ends, but IFRS Foundation has recently established the Accounting Standards Advisory Forum, with the FASB as one of its twelve members Objective is to improve cooperation among worldwide standard setters and advise the IASB as it develops International Financial Reporting Standards The FASB s membership on the ASAF is an opportunity to represent U.S. interests in the IASB s standard-setting process and to continue the process of improving and converging U.S. GAAP and IFRS The final decision regarding whether, when and how to incorporate IFRS into the financial reporting system for U.S. issuers still rests with the SEC Commissioners When might a decision be made? 14

15 What s Wrong with US GAAP Anyway? Pros: International trade and the global capital markets Cons: Adopting IFRS is much more than an accounting exercise. It affects many aspects of a U.S. company's operations, from information technology systems and tax reporting requirements, to internal reporting and key performance metrics and the tracking of stock-based compensation Why don t we just do it? Costs vs. benefits Politics vs. economics Miles vs. kilometres.and also let s all drive on the left! Conclusion: It doesn t matter how you count your beans as long as you count them the same way 15

16 Conclusion Will it Happen and, if so, When? Please consult your crystal ball or local clairvoyant! 16

17 REFERENCES IASB Work plan as at 23 September 2013: Grant Thornton: Comparison between U.S. GAAP and IFRS (May 2013): Ernst & Young: US GAAP versus IFRS - The basics (November 2012): November_2012/$FILE/US_GAAP_v_IFRS_The_Basics_Nov2012.pdf#! PwC: IFRS adoption by country (April 2013): IASeminars current schedule of IFRS and US GAAP courses around the world: 17