ONE SINGLE PAGE FOR ACCOUNTING RESEARCH TOPIC "INCOME TAX"

SOME ISSUES ABOUT THE TRANSITION FROM U.S. GENERALLY ACCEPTED ACCOUNTING PRINCIPLES (GAAP) TO INTERNATIONAL FINANCIAL REPORTING STANDARDS (IFRS) Elena, Hlaciuc; Catalina, Mihalciuc Camelia; Stefana, Cibotariu Irina; Niculina, Apetri Anisoara . Annales

Universitatis Apulensis : Series Oeconomica ; Alba Iulia  Vol. 11, Iss. 1,  (2009): 275-289.

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ABSTRACT The ultimate goal of a move to IFRS International Financial Reporting Standards is the rigorous application of a

single set of global accounting standards, which will produce high-quality, transparent financial information to help

investors and other stakeholders in the world's capital markets make economic decisions based on financial data

that is easily and directly comparable. Many believe this is a necessity for a vital and growing global economy. In

this article the authors tried to present the issue of convergence between US Generally Accepted Accounting

Principles (GAAP) and International Financial Reporting Standards (IFRS). Adoption of IFRS (International

Financial Reporting Standards) in the US undoubtedly would mark a significant change for many US companies. It

would require a shift to a more principles-based approach, place far greater reliance on management (and auditor)

judgment, and spur major changes in company processes and systems. [PUBLICATION ABSTRACT] FULL TEXT Headnote

ABSTRACT: The ultimate goal of a move to IFRS International Financial Reporting Standards is the rigorous

application of a single set of global accounting standards, which will produce high-quality, transparent financial

information to help investors and other stakeholders in the world's capital markets make economic decisions

based on financial data that is easily and directly comparable. Many believe this is a necessity for a vital and

growing global economy. In this article the authors tried to present the issue of convergence between US Generally

Accepted Accounting Principles (GAAP) and International Financial Reporting Standards (IFRS). Adoption of IFRS

(International Financial Reporting Standards) in the US undoubtedly would mark a significant change for many US

companies. It would require a shift to a more principles-based approach, place far greater reliance on management

(and auditor) judgment, and spur major changes in company processes and systems.

Key words: IFRS, US - GAAP, SEC, IASB, FASB

JEL codes: M48 - Government Policy and Regulation

Introduction

Importance of International Financial Reporting Standards (IFRS) has greatly increased in recent years.

International Financial Reporting Standards (IFRS) is a set of accounting standards, developed by the International

Accounting Standards Board (IASB), an independent accounting standards body, that differ from the United States

Generally Accepted Accounting Principals (GAAP) that historically have been used for reporting financial

information in domestic public and private companies and other organizations. Today, more than 100 countries

use IFRS for public reporting purposes. The SEC has issued a roadmap as to how US companies will forge ahead

to report using IFRS. Both IFRS and US GAAP share the same general principles and conceptual framework.

However, US GAAP is more rules based, whereas IFRS is more principles based. Perhaps the greatest difference is

that IFRS provides much less overall detail. Most of the changes that will be encountered between US GAAP and

IFRS will not necessarily impact the reporting at the hotel property level. US companies will spend between 0.125%

and 0.13% of their revenue on making the transition. The SEC will be deciding in 2011 whether to require US

companies to report using IFRS. Taking a proactive approach and making preparations for a change would be a

prudent decision. A change from US GAAP to IFRS is not only a financial reporting one, but in many cases a

change in management as key performance indicators, employee and executive compensation, investor relations

and legal issues will potentially be affected by the change.

Revolutionary changes are occurring in accounting and financial reporting in the US and other countries. Until

2008, the Securities and Exchange Commission (SEC) in the US required for financial reporting by companies

traded in the US stock market, that their financial statements either follow US generally accepted accounting

principles (GAAP) or be reconciled to US GAAP. The SEC did not accept the International Financial Reporting

Standards (IFRS) issued by the International Accounting Standards Board (IASB). Until the early 2000s, securities

commissions in most countries took the same basic position toward IFRS as did the United States SEC.

Starting in the mid-2000s, a series of events, notably in the US and European Union, greatly advanced worldwide

acceptance of IFRS. This study seeks to determine whether IFRS are an unstoppable juggernaut for US and global

financial reporting. To make this determination, a review of recent events includes a longitudinal analysis of

adoption of IFRS by the countries of the world. Also, perspectives about IFRS held by top corporate accounting

officers among Fortune 500 business firms will be obtained and evaluated.

Reasons to move to a global IFRS

Many questions are linked by the transition from the Generally Accepted Accounting Principles (GAAP) to IFRS.

- Why are IFRS attractive as the ultimate global standard?

The IFRS are developed by the International Accounting Standards Board (IASB) in London in collaboration with

the Financial Accounting Standards Board (FASB) and other global accounting standard-setters. As principles-

based system, IFRS can allow issuers to reflect more fully the economic substance of transactions that may be

unique to their industry, compared with a prescriptive, rules-based system such as GAAP.

- Are there potential disadvantages to converging standards?

Some investors feel a principles- based system provides too much management discretion. Others fear losing

information contained in extensive disclosures under US GAAP and SEC regulations. Also, IFRS is arguably less

robust than GAAP in areas such as lease accounting, principles of revenue recognition and accounting for the

insurance industry.

Second, implementation could confuse investors if it were phased in. The SEC proposals allow certain US firms to

use either IFRS or GAAP or both, forcing investors and issuers to learn and apply two standards simultaneously.

The SEC proposal may also mistakenly assume that firms will voluntarily commit to significant IFRS development

costs in the absence of a mandated deadline. Another potential downside is that IFRS may not in fact improve

international comparability if firms and regulators apply principles- based standards differently. There is no single

enforcement body to ensure IFRS are interpreted and applied in a uniform fashion.

A move to IFRS also presents a tremendous opportunity. Moving to an entirely new accounting structure

ultimately might enable companies to streamline reporting processes and reduce compliance costs. While there

are differences between US GAAP and IFRS, the general principles, conceptual framework and accounting results

between them are often the same, or similar, for most commonly-encountered transactions. With IFRS likely to

arrive in the near - rather than distant - future, affected utilities should consider the implications of IFRS and start

planning now. The resources needed and the impact on the organization will be far-reaching. But with proper

strategic planning, benefits can be substantial.

The US Securities and Exchange Commission (SEC) have proposed rules ultimately requiring US issuers to use

International Financial Reporting Standards (IFRS) rather than the US Generally Accepted Accounting Principles

(GAAP).

- Does a global accounting standard benefit investors?

As markets become increasingly global, it is important to be able to rely on financial reporting and make

international comparisons, both of which require a uniform set of high quality accounting standards. Investors also

stand to benefit from a single financial "language" with which to interpret corporate activities. IFRS is currently

required for all domestic listed entities in 85 jurisdictions and allowed in 113 jurisdictions.

- What are the possible barriers to implementing uniform global standards?

First, local standards such as US GAAP need to be harmonized with IFRS. The IASB and FASB are working on a

project to last until the end of 2011 to address the most important technical differences.

Second, implementation could confuse investors if it were phased in. The SEC proposals allow certain US firms to

use either IFRS or GAAP or both, forcing investors and issuers to learn and apply two standards simultaneously.

The SEC proposal may also mistakenly assume that firms will voluntarily commit to significant IFRS development

costs in the absence of a mandated deadline. A further challenge to convergence is politicization of local

standards. For example, the application and enforcement of IFRS standards in the European Union, which adopted

IFRS in 2005, have been varied and influenced by local interests.

- Is there an alternative approach for implementation?

Another approach is to complete the harmonization of GAAP and IFRS before converging to a single standard and

selecting a single adoption date for all firms. This approach could reduce confusion and complexity. It might also

provide time for investors and stakeholders to move smoothly to a single standard.

It is also important to establish a "road map" for ultimate adoptions for issuers, investors and other stakeholders.

- How will investors adapt to converged standards?

Learning a new "language" for accounting and reporting certainly requires time and effort for education. Investors,

issuers, auditors and regulators will all need to learn and understand IFRS, which will require training across the

board.

- What is a reasonable time frame for adoption?

Requiring adoption by 2014 is reasonable. It allows time for reporting standards to converge and for the necessary

training and education. An interim period of allowing a dual system now rushes matters. Given the vital role

financial statements play in the world's capital markets, it is advisable to adopt a more deliberate, less

experimental pace that ensures everyone is well- prepared. In April 2004, FASB and the International Accounting

Standards Board created a joint project on financial statement presentation. The project is part of the

memorandum of understanding between the two bodies that set out a road map for convergence between IFRS

and US GAAP. The goal is to create a common standard for the form, content, classification, aggregation and

display of line items on the face of financial statements. The project applies to public and private business entities,

but not to nonbusiness entities such as not-for-profits or defined-benefit plans.

The question is seemingly no longer "if," but "when" the United States will adopt International Financial Reporting

Standards (IFRS). In a forum held this past June at Baruch College in New York City, the Financial Accounting

Standards Board (FASB) addressed the question of when and how the United States would move to IFRS.

Participants in the forum included top officials from the FASB, the Financial Accounting Foundation (FAF), the

Financial Accounting Standards Advisory Council (FASAC), the International Accounting Standards Board (IASB),

the SEC, the AICPA, the Financial Executives Institute (FEI), the Institute of Management Accountants (LMA), the

CFA Institute, the Public Company Accounting Oversight Board (PCAOB), and the American Accounting

Association (AAA). Additional participants included individuals representing financial statement users, small and

large companies, auditors, regulators, educators, and other parties that might be affected if there is a move from

U.S.

Among the issues discussed at the forum included: whether U.S. GAAP should ultimately converge with IFRS and,

if so, how and when; how to pre- pare the United States for a shift to IFRS; accounting education and pro- fissional

certification; regulatory and tax issues; the potential effects on private companies and not-for-profit entities; and

the future role of the FASB. SEC Chief Accountant Conrad Hewitt said that one important issue would be whether

U.S. companies should have the option of moving to IFRS, and whether this option should be phased in over time,

with large companies going first Several groups, such as the CFA Institute, opposed allowing U.S. companies the

option to adopt IFRS, preferring a mandate from the SEC instead. Others recommended giving companies a five-

year lead time to adopt IFRS, with a single deadline for adoption. Finally, other groups, such as the IMA, favored the

optional approach, but with a shorter, three-to-five-year timeframe to get acquainted with IFRS.

Subsequent to the roundtable, in August 2008, the SEC voted to publish a proposed road map that could lead to

the use of IFRS by U.S. companies beginning in 2014. The SEC plans to make a decision in 2011 on whether the

adoption of IFRS is in the public interest and would benefit investors. The proposed multiyear plan sets out several

milestones that, if achieved, could lead to the use of IFRS by U.S. companies in their SEC filings.

- What Has Prompted Convergence Toward IFRS?

The issue of convergence between U.S. GAAP and IFRS has been developing for some time. Issued in August

2007, SEC Concept Release 33-8831 addressed the question of whether U.S. companies should be allowed to

prepare their financial statements in accordance with IFRS. An SEC ruling issued in December 2007 allows foreign

private companies to use IFRS without reconciling to U.S. GAAP. These actions have raised the importance and

the urgency of this issue. FASB Chairman Bob Herz stated at the June 2008 FASB forum that the organization

faces the challenge of "riding two horses at the same time" until convergence is achieved. To avoid this problem,

the FASB has indicated in its response to the SEC concept release that investors would be better served if all U.S.

public companies were to use a common set of international accounting standards, which would be best

accomplished by moving U.S. companies toward IFRS. Thus, a move to LFRS appears to be inevitable.

Nevertheless, there are a number of challenges to the adoption of IFRS, and thus the question arises:

- What's the hurry? Shouldn't we take the time to get it right?

As various countries around the world have moved to IFRS, one particular issue often comes up:

- What about small and medium-sized enterprises?

The IASB has addressed this matter by issuing an exposure draft of a proposed IFRS for small and medium-sized

enterprises (SME). The IASB also develops and publishes a separate standard intended to apply to the general

purpose financial statements of, and other financial reporting by, entities that in many countries are referred to by

a variety of terms, including small and medium-sized entities (SME's), private entities, and non-publicly

accountable entities. That standard is the International Financial Reporting Standard for Small and Medium-sized

Entities (IFRS for SME's).

Small and medium-sized entities are entities that:

- do not have public accountability, and

- publish general purpose financial statements for external users. Examples of external users include owners who

are not involved in managing the business, existing and potential creditors, and credit rating agencies.

On July 2009 the International Accounting Standards Board (IASB) issued an International Financial Reporting

Standard (IFRS) designed for use by small and medium-sized entities (SME's). The standard is a result of a five-

year development process involving extensive consultation with SME's worldwide.

The IFRS for SME's responds to strong international demand from both developed and emerging economies for a

rigorous and common set of accounting standards for smaller and medium-sized businesses that is much simpler

than full IFRS's. In particular, the IFRS for SME's will:

- provide improved comparability for users of accounts;

- enhance the overall confidence in the accounts of SME's;

- reduce the significant costs involved of maintaining standards on a national basis;

- also provide a platform for growing businesses that are preparing to enter public capital markets, where

application of full IFRS's is required.

The IFRS for SME's is separate from full IFRS's and is therefore available for any jurisdiction to adopt whether or

not it has adopted the full IFRS's. It is also for each jurisdiction to determine which entities should use the IFRS for

SME's.

The IFRS for SME's is a self-contained standard of about 230 pages tailored for the needs and capabilities of

smaller businesses. Many of the principles in full IFRS's for recognising and measuring assets, liabilities, income

and expenses have been simplified, topics not relevant to SME's have been omitted, and the number of required

disclosures has been significantly reduced. To further reduce the reporting burden for SME's, revisions to the IFRS

for SME's will be limited to once every three years. The IFRS for SME's even includes its own "framework" in

section 2 Concepts and Pervasive Principles. The IFRS for SME's only allows, but does not require, its users to

refer to full IFRSs when addressing financial instruments.

In May 2008, the IASB reconsidered the SME exposure draft in light of comment letters and field tests. Among the

matters decided by the IASB were the following: The title of the standard will be changed to "International Financial

Reporting Standard for Private Entities," with private entities being defined as companies that do not have public

accountability (in the United States, essentially a nonpublic company). Thus, the size of the business will not be a

factor in determining whether a company uses simplified IFRS. The only deciding factor will be whether the

company is private or public.

The standard will be stand-alone, with no reference to the main body of IFRS. Thus, there would be two categories

of GAAP - one for public companies and one for private companies. All accounting options in the full set of IFRS

would be available to private entities. The IASB standard will not address the following topics: lease accounting,

share based payments, segment information, earnings per share, and interim reporting. Any company with publicly

traded shares would not be allowed to use simplified IFRS.

Any entity whose primary business is holding money on a fiduciary basis would not be allowed to use simplified

IFRS.

A subsidiary of a company using full IFRS would have to provide all of the disclosures required by full IFRS.

Simplified IFRS will not prescribe financial statement formats, titles, subtotals, minimum line items, sequencing, or

note disclosures; however, the standard will require a statement of comprehensive income.

Unless the requirement to move from US GAAP to IFRS applies only to publicly traded companies, there will be two

GAAPs: a big GAAP and a little US GAAP financial accounting standards setters have avoided this problem for

more than 50 years. Typically, there is no difference between GAAP for big companies and GAAP for small

companies. In certain cases, nonpublic companies are exempted from several GAAP requirements (e.g., earnings

per share and segment reporting), but except for these relatively limited cases, there are no significant differences

between big GAAP and little GAAP. In contrast, pursuant to IFRS, there will be an explicit distinction between full

IFRS and the simplified IFRS applicable to private companies. This may be an inevitable result of moving to IFRS,

but it will be something new to US accounting standards. Accounting practitioners, regulators, creditors,

educators, and even law court judges will need to adjust their thinking regarding the idea that GAAP will no longer

mean "generally accepted" accounting principles. Instead, there will have to be an explanation concerning which

set of accounting principles applied in a particular case, not-for-Profit and Governmental Entities.

While some countries have decided that IFRS should apply to not-for-profit organizations, IFRS is not actually

intended to apply to such entities. If the SEC mandates that US companies move to IFRS, there will probably be no

similar requirement that not-for-profits move to IFRS. Therefore, most not-for- profits will not make the switch. As

in the case of small and medium-sized businesses, there will be a different type of GAAP for not-for-profit

organizations. Also, there is no IFRS for governmental entities, even though in some countries, such as Australia

and the United Kingdom, there has been an effort to implement IFRS for both not-for-profit and governmental

entities. If the SEC requires U.S. public companies to move to IFRS, this would not change the status of the

Governmental Accounting Standards Board (GASB) or GASB's responsibility to set GAAP for governmental entities.

The previous coordination among the staffs of the FASB and the GASB has led to improvement in accounting for

both not-for-profit entities and governmental entities. If the FASB is no longer responsible for setting U.S. GAAP,

the question arises whether GAAP for not-for-profits will continue to be established by the FASB. One vision of the

future would be a tripartite division of GAAP-IFRS for publicly traded companies, simplified GAAP for small and

medium-sized companies, and another sort of GAAP for not-for-profit and governmental entities. In essence, there

would no longer be a uniform concept of GAAP, but a GAAP as applied to different types of entities.

- What about tax issues?

There are a number of differences between IFRS and U.S. GAAP that may materially affect financial reporting and

tax planning. Some examples include: revenue recognition, lease accounting, asset impairments, financial

instruments, hedging activities, and stock-based compensation. U.S. tax law does not necessarily correspond with

U.S. GAAP. A move to IFRS will therefore require an analysis of tax implications, including a determination whether

making the tax method conform to the book method will even be allowed. Tax accounting methods do not

automatically change because the financial accounting method changes. The consent of the IFRS commissioner

must often be obtained in order to change an accounting method.

While not the most important conceptually, perhaps the stickiest problem deals with last-in, first-out (LIFO)

accounting. Simply put, under IFRS, companies are prohibited from using LIFO. But under US law, US companies

must use LIFO in their published and audited financial statements to obtain the tax benefits of LIFO. The Financial

Accounting Standards Board and the US Securities and Exchange Commission are fully aware of this problem and

are taking steps to mitigate it. One suggestion would be for Congress to change the tax law and permit use of LIFO

for taxes and repeal the conformity requirement. Under both US GAAP and IFRS all research costs must be

expensed as incurred. Development costs, however, can be capitalized under IFRS if they meet the criteria for an

intangible asset. With respect to valuation-related issues, adoption of IFRS will probably require a new mindset by

financial executives regarding reported income

Last in, first out (LIFO) accounting will be a thorny issue: IFRS does not permit LIFO, but U.S. tax law requires LIFO

accounting for financial reporting purposes, if LIFO is elected for tax purposes. Thus, unless the LIFO conformity

requirement is changed through federal legislation, U.S. companies using LIFO will face a tax liability if they move

to IFRS.

Conversion to IFRS is also likely to have an impact on tax planning and cash repatriation from foreign subsidiaries.

There will be implications for foreign tax credit and Subpart F calculations. There will also be an impact on

earnings and profits computations in order to maintain consistency with accounting methods. The ability to make

distributions from foreign affiliates may also be affected to the extent that IFRS results in a change in the

distributable reserves of a subsidiary. In countries where statutory accounting forms the basis for defining debt

versus equity for purposes of calculating allowable deductions for interest and dividend distributions, the use of

financing structures will need to be reviewed. In addition, in some countries, the characterization of a transaction

as a lease depends upon the accounting for tax purposes. The use of fair value measurements is also central to

IFRS. For example, under IFRS, companies can elect to measure property and equipment at fair value, and financial

instruments are required to be carried at fair value. These measurement concepts can have a significant impact on

debt-to-equity and other balance- sheet ratios, resulting in limitations on the deductibility of interest. Another issue

involves the question of uncertain tax positions. The IASB has indicated that it will not adopt FASB Interpretation

48 (FIN 48), Accounting for Uncertainty in Income Taxes. This means that U.S. companies moving to IFRS may

need to change the way they account for uncertain tax positions. IFRS does not prescribe a specific approach to

measurement of uncertain tax positions, and the IASB has decided to move to a model with no recognition

threshold for uncertainties and measurement using weighted average probability. This is less prescriptive than FIN

48.

Consequently, adoption of IFRS would cause all current LIFO reserves - amounting to billions of dollars - to

immediately become taxable income. This alone represents a prohibitive cost barrier.

The Financial Accounting Standards Board and the U.S. Securities and Exchange Commission are fully aware of

this problem and are taking steps to mitigate it. One suggestion would be for Congress to change the tax law and

permit use of LIFO for taxes and repeal the conformity requirement. Given the need for tax revenue, however, a

more likely scenario would be a 10-year transition. On a present-value basis, this would mitigate but not eliminate

the problem. No matter how any LIFO spread is handled, companies currently using LIFO will likely have significant

out-of-pocket cash cost on adopting IFRS. Even 'Fair Value' Definition Differs When FASB issued its Financial

Accounting Standard No. 1 57, Fair Value Measurements; it introduced a unique definition of fair value, in part, to

distinguish it from the more common fair-market value definition. (FEI wrote to FASB, before issuance of SFAS 157

regarding the new definition.). The new definition of fair value differs from fair-market value in two critical areas.

First, rather than dealing with an exchange between a "willing buyer and willing seller," as used in the fair-market

value definition, fair value requires an exit approach, in other words, you only look to see what you could sell an

asset for, even if you just bought it yesterday.

The second difference deals with a requirement that the fair value be determined on the basis of what some

theoretical market participant might pay, rather than looking at an actual transaction.

The best way to comprehend the significance of these two points is to consider an art auction. Suppose the

winning bidder for a Picasso painting won at $30 million. The last competitor had dropped out at $29 million.

Under the SFAS 1 57 fair value definition, the buyer would have to take an immediate impairment charge of $1

million. He would value the Picasso only at what he could sell it for; the only market participant has already

signaled that he is unwilling to pay more than $29 million.

The members of the International Accounting Standards Board so far have not adopted the FASB definition of fair

value and the jury is out as to what will ultimately be decided. Meanwhile, the definitions of fair value continue to

differ.

Challenges of Moving to IFRS

There are some aspects of IFRS which do not exist in US GAAP. For example, International Accounting Standard

41 (IAS 41) prescribes the accounting treatment for agricultural and biological assets. IAS 41 requires

measurement of biological assets at fair value, up to the point of harvest For example: A fish farm in Norway must

apply a fair value standard to its salmon stock during the period that the salmon grows from an egg to a full-grown

fish ready for harvesting. The increase in value is reported in the statement of profit and loss. The question is:

What is the value of a halfgrown salmon? Likewise, a forest products company in Finland must apply a fair value

standard to its trees that grow and reach maturity over a period of 20 or more years. If the SEC decides to move

from US GAAP to IFRS, it is likely that there will be a certain degree of confusion and incomprehension regarding

this standard. IFRS is often considered to be more principles-based than US GAAP. While this may be true, a

principles-based approach poses some problems. For example, IAS 17, which deals with lease accounting,

specifies that: "At the commencement of the lease term, lessees shall recognize finance leases as assets and

liabilities in their balance sheets at amounts equal to the fair value of the leased property or, if lower, the present

value of the minimum lease payments, each determined at the inception of the lease." IAS 17 also specifies that:

"A lease is classified as a finance lease if it transfers substantially all the risks and rewards incidental to

ownership." There is no specific guidance regarding the defining characteristics of a lease that "transfers

substantially all the risks and reward incidental to ownership." Under such a standard, U.S. auditors may find it

difficult to persuade their clients that they must record a lease as a finance lease.

A difficult transition

While it may not be difficult for a multinational enterprise to move from US GAAP to IFRS in the near future, a point

echoed by participants in the June FASB forum, small and medium enterprises, agricultural enterprises, not-for-

profit organizations, and governmental entities may find the challenge of moving to IFRS to be insurmountable.

One of the results of moving from US GAAP to IFRS for publicly traded companies may be that, for the first time in

the history of U.S. accounting standards setting, there will be multiple types of GAAP. This may not be a difficult

problem to deal with, but practitioners, regulators, lenders, courts, and educators will need to come to grips with

the fact that GAAP will no longer be "generally accepted" accounting principles. Secondly, in certain areas, such as

the fair value measurement of agricultural products, there is currently no US GAAP in effect.

- What will we make of this change and will it be readily applied to the U.S. farming industry? Finally, IFRS is

considered to be more principles-based, but in a litigious environment such as the United States, a principles

based approach may often lead to lawsuits.

- Will U.S. auditors be willing to make firm judgments about the gray areas of accounting without the authority of

U.S. GAAP standing behind them?

One vision of the future would be a tripartite division of GAAPIFRS for publicly traded companies, simplified GAAP

for small and medium-sized companies, and another sort of GAAP for not-for-profit and governmental entities.

IFRS has fewer bright lines and less interpretive and application guidance than does US GAAP (Generally Accepted

Accounting Principles). Companies will need to consider carefully the economic substance of their transactions

and then apply the principles embodied in IFRS to that substance. Arguably, doing so might enable a closer

alignment with underlying business objectives. Many financial professionals in the power and utility industries

today are aware of IFRS, which presently is used or under consideration in every major financial market around the

world. There is a growing recognition, both in the United States and internationally, that a single set of high-quality

global accounting standards offers teal benefits. IFRS seems increasingly likely to provide that single set of

standards.

Literature review

Nations of the world have engaged in global commerce since the beginning of recorded history. If international

trade occurs, accounting and financial reporting are useful for recording and reporting the results. Global

operations are becoming more important to all types of business firms. Many firms are increasing their

international operations and the number of countries in which they do business. A greater number of business

firms are now providing products and services to customers around the world.

Information asymmetry between management and external stakeholders is increased for firms functioning in a

complex environment. Multinational firms carry on business in a more complex environment than strictly domestic

firms (Runyan and Smith 2007). Globalization of business and capital markets has led to an economic

environment in which uniform procedures for financial statement preparation would benefit investors, lenders,

financial analysts, accountants, and auditors (Gaspar et al. 2006). Uniformity in accounting standards helps

provide comparability of financial statements among companies in diverse country locations. The International

Accounting Standards Board (IASB) is endeavoring to develop harmonized financial accounting standards to

satisfy worldwide demands. Companies engaged in international business encounter a variety of challenges as a

result of their global operations. Challenges result from different cultures, language differences, different legal

systems, political differences, different operating environments, and different accounting and financial reporting

standards. Much past research examines the effect of culture on accounting and business. Some representative

recent and older studies include Karahanna et al. (2005), Patel (2004), Blanco and Osma (2004), Davison and

Martinsons (2003), Hofstede et al. (1990), Hofstede and Bond (1988), and Hofstede (1984). Karahanna et al. (2005)

consider cultural levels and their impact on individual behavior. Patel (2004) examines theoretical strengths and

weaknesses of prior research regarding accountants' values and judgments. Blanco and Osma (2004) review

differences between US GAAP and International Financial Reporting Standards, by looking at Form 20-F

reconciliations in the period 1995-2001. They find that significant differences exist, but that international

standards and US GAAP appear to be converging. Hofstede (1984) provides foundational work concerning the

effect of culture on business activities. Herrmann and\ Hague (2006) indicate that international accounting

standards and US GAAP increasingly influence each other. They note that the US Financial Accounting Standards

Board and the IASB entered into a memorandum of understanding formalizing their commitment to converge on a

single set of accounting standards in 2002. This convergence effort makes it important for US accountants to

understand how the conformance of a US accounting standard to an international standard can significantly affect

US companies.

Fontes et al. (2005) analyzed three methods for measuring success attained in achieving convergence between

two sets of accounting standards. They reviewed a measurement method based on the concept of Euclidian

distances. They proposed two better measures of assessing progress of national accounting standards setting

bodies in converging their standards with IFRSs. For illustrative purposes they measured convergence of national

standards in Portugal with international standards over the period 1977-2003. Mir and Rahaman (2005) evaluated

the decision of the Bangladeshi government and accounting profession to adopt international standards. These

researchers used archival data and interviews of key actors, including preparers and users of financial reports,

members of the SEC, and members of professional accounting bodies. Results indicate that institutional

legitimization is a key factor that drives the decision to adopt international standards.

The International Organization of Securities Commissions (IOSCO) and the individual securities commissions,

which make up the IOSCO, play a key role in determining worldwide acceptance of international standards. Over 60

securities regulatory agencies worldwide comprise the IOSCO. The US Securities and Exchange Commission is a

member of the IOSCO. A major objective of the IOSCO is to facilitate cross-border securities offerings and multiple

listings without compromising the financial statement information provided (Gaspar et al. 2006). IASB member

Patricia L.O'Malley (2004), in a speech to the International Accounting section of the American Accounting

Association, cited lower financial statement preparation costs as a benefit of reducing differences in accounting

standards among nations. Resolving differences in multiple GAAPs can be a substantial cost to multinational

business firms. Multinational firms with tens and even hundreds of subsidiaries must translate host country

financial statements into home country statements. The process of consolidating parent and subsidiary

statements is a massive and complex process. In a pivotal event in 2005, the European Union (EU) required use of

IFRS in consolidated financial statements of all EU listed companies, about 9,000 companies. Approximately 400

EU firms are traded on US markets. Besides the EU countries, many other countries have adopted IFRS almost

word for word as their national GAAP. Countries adopting IFRS include: Australia, New Zealand, South Africa,

Singapore, Hong Kong, and the Philippines. Some countries that have stopped developing a national GAAP and

just use IFRS include: Bahrain, Croatia, Costa Rica, Cyprus, Dominican Republic, Ecuador, Guatemala, Haiti,

Honduras, Jamaica, Kenya, Malta, Mauritius, Nepal, Oman, Panama, Tanzania, Tajikistan, Trinidad, and United Arab

Emirates (Praeter 2003).

In December 2007, the Securities and Exchange Commission revised its rules so that non- U.S. companies will be

permitted to include in their SEC filings financial statements without reconciliation to US GAAP if the financial

statements are prepared in accordance with IFRS as issued by the International Accounting Standards Board

(IASB). This is a landmark event in US financial reporting, as acceptance of IFRSs removes a major obstacle for

foreign private issuers to enter and to remain in the US markets (Deloitte Touche Tohmatsu 2008, Gibson, Dunn

and Crutcher 2008, Bergman et al. 2008).

The SEC seems on the verge of accepting IFRS, not just for non-US companies trading in the US stock market but

for US-based companies, as well. Among those calling for acceptance of IFRS are John Thain from the New York

Stock Exchange and former Federal Reserve Chairman Paul Volcker (White 2007). FASB Chairman Robert Herz has

expressed his expectation that US companies would eventually be required to follow a single accounting standard,

which would be IFRS (Leone 2007).

The ongoing globalization and resulting complexity of business makes accounting financial reporting a technically

demanding and oftentimes daunting process. Across countries, accounting standards diverge as a result of unique

cultural, political, legal, and economic factors. Effective and efficient functioning of the global marketplace

necessitates uniformity in accounting standards. At the current time, businesspersons, financiers, and investors

must take into consideration the differences that exist. Such differences substantially curtail the development of

international business activity.

Harmonization of standards has the potential of benefiting economic activity around the globe (Gaspar et al.

2006). As far back as the beginning of recorded history, peoples of the world have participated in global

commerce. As long as international trade has occurred, accounting is useful for recording and reporting the

results. Multinational operations are increasingly important to all types of business firms. Numerous multinational

firms are either expanding international operations, or becoming part of other multinational firms via mergers or

acquisitions. Consequently, more firms than ever before are providing products and services to customers around

the globe.

The internationalization of business and capital markets has resulted in an economic environment in which

uniform procedures for financial statement preparation would benefit investors, lenders, financial analysts,

accountants, and auditors (Gaspar et al. 2006). Uniformity facilitates comparability of financial statements among

firms of diverse country locations. The International Accounting Standards Board (IASB) is endeavoring to develop

harmonized financial accounting standards to satisfy worldwide demands. Numerous multinational firms are

required or voluntarily choose to follow international standards in preparing their financial reports.

2008 NOV 3 - (VerticalNews.com) - Many U.S. companies have not begun preparations for the possible transition

from the current Generally Accepted Accounting Principles (US GAAP) to International Financial Reporting

Standards (IFRS), according to a survey conducted by Protiviti Inc., a global business consulting and internal audit

firm. The survey also finds a number of challenges for companies in making the conversion to IFRS, including the

expense of upgrading IT systems to finding the right talent to make the transition smooth and efficient.

Throughout the world, regulatory agencies and investors have sought out a consistent worldwide standard for

financial reporting, resulting in the U.S. Securities and Exchange Commission (SEC) publishing a proposed

roadmap for large corporations to switch to international accounting standards by 2014. Under this proposed plan,

more than 100 companies may be able to start following IFRS with their 2009 financial statements. Now is the

time for companies to begin determining the steps they will need to take to ensure that their conversion to IFRS is

as seamless and cost-effective as possible," said Christopher Wright, managing director with Protiviti and one of

the firm's global leaders of IFRS services. "Conducting a diagnostic review of everything from financial policies and

disclosures to data flows is strongly recommended now to scope out all the possible ways a company and its

finance function could be impacted."

As head of the accounting profession's largest association, Melancon serves as a member of the AICPA's

delegation to the International Federation of Accountants, whose broad objective is the development and

enhancement of a coordinated worldwide accountancy profession with harmonized standards. Melancon says the

interconnected financial markets underscore the need for consistent standards and predicts the move to IFRS in

the United States will likely be led by the Securities and Exchange Commission (SEC), which began encouraging an

international set of standards in 1988. Although the commission is likely to undergo changes under a new

presidential administration, it recently called for a roadmap that could lead to IFRS being used in the United States

by 2014. "The world's capital markets have long searched for a single set of high quality accounting standards that

can be used anywhere on earth," notes current SEC Chairman Christopher Cox. "The proposed roadmap is cautious

and careful. It's a proposed multi-year plan."

Research methodology

The main objectives of this paper refers to the issues related to the US transition to IFRS, whole these issues

proposed by some authors being founded in a brief review of the literature written on the topic till 2009. To achieve

the objectives that were proposed, we analyzed over 20 academic articles indexed in different international

database that were available and also the site of IASB.

In general, IFRS standards are broader than their US counterparts, with limited interpretive guidance. While US

standards contain underlying principles as well, the strong regulatory and legal environment in US markets has

resulted in a more prescriptive approach - with far more "bright lines," comprehensive implementation guidance

and industry interpretations. The International Accounting Standards Board (IASB) generally has avoided issuing

interpretations of its own standards, preferring instead to leave implementation of the principles embodied in its

standards to preparers and auditors, and its official interpretive body, the International Financial Reporting

Interpretations Committee (IFRIC).

In any case, momentum is building for US adoption of IFRS, and conversion no longer appears to be a matter of "if,"

but more a matter of "when" and "how." For companies that report in multiple jurisdictions, the adoption of a single

global set of accounting standards can be a benefit in terms of process standardization and related efficiency

gains. Multiple approaches to financial reporting continue to be inefficient and troublesome, and many affected

companies strongly support the SECs continued efforts in the US transition to IFRS. The question that power and

utility executives and directors need to tackle sooner, rather than later - is how they can maximize the

opportunities presented by IFRS and effectively and efficiently deal with any challenges as a result of the

conversion. The straightforward answer is to start planning now, dedicate the appropriate management focus and

create a project team across all aspects of the company - including the financial accounting and reporting, tax and

IT departments - to assess the effort and work toward transition activities. Also, it's never too early to begin

educating analysts and investors on how a conversion to IFRS might impact the company's financial results. Now

is the time to begin planning for conversion from GAAP to IFRS. The resources needed and the impact on the

organization will be far-reaching. But with proper strategic planning, benefits can be substantial.

Five steps to implementing

Step 1: Develop goals:

The company's management team and board of directors decide how best to present the company's financiers on

an ongoing basis. Then, preliminary mapping begins and high-level risk assessments are conducted, outlining the

potential impact that IFRS can have on the company's balance sheet, financial reporting and accounting policies,

tax liabilities, and contracts and joint venture agreements.

Step 2: Design and planning:

The transition team validates the conversion recommendations made in Step 1 and evaluates the various options

to determine the impact that different financial accounting and reporting policies will have across the enterprise.

Step 3: Solution development:

New IFRS policies are modeled, and the transition team develops the process and system change requirements

that the new guidelines require.

Step 4: Implementation:

At its heart, implementation is a straightforward change-management effort that includes communication and

training, followed by carrying out the agreed-upon approaches. At this step, the transition team can begin to test

the new guidelines as implemented and remediate as needed.

Step 5: Post-implementation review:

This occurs when all key parties- financial accounting and reporting, treasury, tax and others-meet to debrief and

identify opportunities for improvement.

These five steps might take as long as two or three years from initial diagnostic discussions to post-

implementation changes. This period allows for a thoughtful, well-planned transition that increases the long-term

benefit of IFRS. Companies that wait-until either the SEC determines a definitive timeline or their competitors

accelerate efforts toward transition-might find themselves playing catch-up.

This study reviews International Financial Reporting Standards and how their use worldwide has dramatically

increased in recent years. A review of prior research shows that IFRS have the potential to improve the function of

capital markets and facilitate economic progress. Based on the longitudinal analysis of adoption of IFRS by the

countries of the world, there appears to be significant momentum for eventual adoption of IFRS worldwide,

including in the U.S. The U.S. already accepts IFRS for non-U.S. firms traded in the U.S. markets. Eventual

acceptance of IFRS for U.S.-based firms seems quite probable. A survey of perspectives about IFRS revealed that

top corporate accounting officers are highly favorable to acceptance of IFRS for financial reporting by all

companies in all countries, including the U.S. Combining the favorable perspectives of top accounting officers with

the increasingly widespread adoption of IFRS in countries around the world, IFRS seem to be an unstoppable

juggernaut for US and global financial reporting. Based on this analysis, acceptance of IFRS in virtually all

countries, including the U.S., appears imminent, perhaps occurring within the next few years.

Future research could investigate the benefits and problems associated IFRS. Future research could develop a

longitudinal analysis of how international standards change over time. In addition, future research could evaluate

the economic benefits of using international standards at the micro (corporation) level and macro (national or

global) level. Future research could consider whether adoption of international standards leads to easier access by

a firm to foreign capital markets, lower cost of capital, and financial transparency.

Conclusions

IFRS, which aims to create a set of common financial reporting benchmarks for companies worldwide, is seeing

growing acceptance within the US accounting profession, according to the Washington, D.C.-based American

Institute of Certified Public Accountants.

Already, the European Union, Australia, New Zealand, Canada and Israel have accepted IFRS as the standard for

publicly held companies; the US Securities and Exchange Commission is currently weighing whether or not the

new standards should be made mandatory for US companies.

Fifty-eight percent (58%) of US companies are unprepared to train staff for the transition from US Generally

Accepted Accounting Principles (GAAP) to International Financial Reporting Standards (IFRS), according to a new

survey by Ajilon Finance Solutions and the Institute of Management Accountants (IMA). The survey, which polled

approximately 500 finance and accounting professionals as part of IMA's Inside Talk Webinar Series, reveals there

is still a high degree of uncertainty among finance and accounting professionals about the transition to IFRS,

despite the vast majority (86%) of professionals reporting that they anticipate IFRS conversion having a positive

impact on the accounting profession.

Other key findings from Ajilon Finance Solutions' survey reveal: IFRS Expertise Desired: Fifty-two percent (52%) of

respondents said their employers want them to have a general awareness about IFRS and convergence, showing

strong demand for this set of skills/experience. Career Worries are Surfacing: The top three concerns of finance

employees in relation to the convergence of U.S. GAAP and IFRS are: the impact convergence will have on their

future career prospects (58%), that converged standards might be more challenging to apply than current U.S.

standards (26%), and that compliance with converged standards might not be enforced consistently by regulators

throughout the world (24%).

Employees Want Training: The majority (63%) of employees said their company will pay for the cost of training to

get up to speed with IFRS convergence. Most finance employees (61%) prefer Internet-based training in IFRS and

convergence as opposed to classroom or other types of training. "Companies cannot wait until the 2014 deadline

before training and hiring the staff they need for this transition," said Andrew Reina, practice director for Ajilon

Finance Solutions. "We are working with many of our clients now to enable a seamless and efficient transition of

staff and resources in order to ensure that their team is fully prepared, trained and comfortable as soon as

possible." Employers wishing to improve their staff's transition to the new international accounting standards

should take the following steps, according to Ajilon Finance Solutions:

* Conduct a comprehensive diagnostic of existing accounting processes, staff and training resources. It is critical

that organizations create a baseline assessment to identify any gaps in preparedness. It was recommend

identifying an independent source to validate critical migration functions, outline transition costs and perform

impartial staff appraisals.

* Appoint a Project Management Officer. Successful implementations are often a direct result of the leaders

organizing and managing day-to-day activities. Companies need to designate or acquire a seasoned professional

with the critical PMO and accounting expertise to facilitate change management effectively. This liaison should be

a single point of contact for the project deliverables and held accountable to the activity timetables.

* Survey finance employees to ascertain appropriate training methods. Training will be a key component during

IFRS transition. It is important for companies to identify those training delivery mechanisms specific to their

organization. Evaluate feedback from your finance team on what they consider the most effective methods for

training. This could include web seminars, classroom sessions, one-on-one training, onsite versus offsite and

ongoing training requirements.

* Regularly review IFRS adoption procedures. Once IFRS adoption is complete, continue to review accounting

treatments and processes. Conduct periodic best practices assessment to confirm accounting optimization and

guidelines. This is also a good opportunity to reassess ongoing training requirements, how competitors are

reporting and what additional savings can be generated from an infrastructure standpoint.

The Securities and Exchange Commission (SEC) is aware of the growing global acceptance of IFRS and has taken

comments from listed companies, audit firms, investment groups, rating agencies, the legal community and

government agencies in an effort to create a comprehensive plan for a smooth transition to using IFRS in the

United States. These discussions take into consideration issues like whether to allow US filers the option of either

adopting IFRS or setting an effective date for implementation by all US registrants. The SEC hosted a roundtable

meeting in August 2008 that focused on the performance of IFRS during the market turmoil that already was

churning earlier this year. While panelists shared a general consensus that IFRS performed quite well, they

acknowledged that challenges exist in the application of both IFRS and US GAAP in areas such as fair-value

accounting. In addition, the roundtable focused on accounting for off-balance sheet arrangements and commodity

pricing, both topics of particular interest for the power and utility industries. Panelists also expressed the view that

IFRS could benefit from additional application guidance to reduce certain inconsistencies as presently applied.

The philosophical underpinning of the IFRS - in that it is "principles-based," as opposed to that of the US GAAP,

which is "rule-based" - has triggered much debate within publicly held companies, accountants and investors.

While the US financial reporting standards operate around a set of rigid rules, IFRS allows companies more

flexibility, so long as they are seen as consistent with the underlying rules. While there are differences between US

GAAP and IFRS, the general principles, conceptual framework and accounting results between them are often the

same, or similar, for most commonly-encountered transactions.

Regarding the longitudinal analysis of use of IFRS in countries around the world, results suggest a significant

momentum for eventual adoption of IFRS worldwide, including in the US. The US now accepts IFRS for non-US

firms traded in the US markets; eventual acceptance of IFRS for US-based publicly traded firms seems likely.

Regarding the survey of perspectives about IFRS held by top corporate accounting officers, results indicate that

accounting officers are highly favorable to acceptance of IFRS for financial reporting by all companies in all

countries, including the US.

References

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(3 pp.).

2. Bergman, Mark, Yu, Tong, Vaz de Almeida, Patricia. (2008). SEC Agrees to Accept IFRS Financial Statements of

Foreign Private Issuers. Paul Weiss Publications, available on-line at Website: http://www.paulweiss.com, January

8.

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Empirical Study of Form 20- F Reconciliations. International Journal of Accounting, Auditing and Performance

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4. Deloitte Touche Tohmatsu, 2007. IFRSs in Your Pocket, Sixth Edition. Hong Kong, Deloitte Touche Tohmatsu.

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Standards with International Financial Reporting Standards. Accounting Forum, 29, 4: 415-436.

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US and Global Financial Reporting? The Business Review, Cambridge. Hollywood:Summer 2008. Vol. 10, Iss. 1, p.

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International Accounting Standards for U.S. Securities Offerings. Accounting Horizons, 13: 259-280.

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AuthorAffiliation

Hlaciuc Elena1

Mihalciuc Camelia Catalina2

Cibotariu Irina Stefana3

Apetri Anisoara Niculina4

1 "Stefan cel Mare" University of Suceava, Faculty of Economics and Public Administration, Universitatii street No

13, [email protected]

2 "Stefan cel Mare" University of Suceava, Faculty of Economics and Public Administration, Universitatii street No

13, [email protected]

3 "Stefan cel Mare" University of Suceava, Faculty of Economics and Public Administration, Universitatii street No

13, [email protected]

4 "Stefan cel Mare" University of Suceava, Faculty of Economics and Public Administration, Universitatii street No

13, [email protected] DETAILS

Subject: Studies; International Financial Reporting Standards; GAAP; Transitions

Location: United States--US

LINKS Check for fulltext availability

Classification: 9130: Experiment/theoretical treatment; 4120: Accounting policies &procedures;

9190: United States

Publication title: Annales Universitatis Apulensis : Series Oeconomica; Alba Iulia

Volume: 11

Issue: 1

Pages: 275-289

Number of pages: 15

Publication year: 2009

Publication date: 2009

Publisher: "1 Decembrie 1918" University of Alba Iulia (Romania), Faculty of Sciences

Place of publication: Alba Iulia

Country of publication: Romania, Alba Iulia

Publication subject: Business And Economics

ISSN: 14549409

Source type: Scholarly Journals

Language of publication: English

Document type: Feature

Document feature: References

ProQuest document ID: 807501880

Document URL: http://proxy.library.cpp.edu/login?url=https://search.proquest.com/docview/807501

880?accountid=10357

Copyright: Copyright "1 December 1918" University of Alba Iulia (Romania), Faculty of Sciences

2009

Last updated: 2011-05-27

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