Friday, April 28, 2017

Moving the blog


I am moving this blog to the company web site, www.ez13.com/blogs. When I started this blog, our web site couldn't run a blog, but updates have made that possible, and it seems better to have everything in one place.


I will leave the existing posts here, but all future posts will only be at the blog on our web site. Please join me there!

Wednesday, July 13, 2016

Summary of IFRS 16 differences with ASC 842



This is a bit later in posting than I had intended, but below is a review of the substantive differences between IFRS 16, the new lease accounting standard for entities covered by international financial reporting standards, and ASC 842, the equivalent new standard under US GAAP. Please look at my previous review of ASC 842 for general comments on the new lease accounting regime, including those that apply to both standards.

(Almost) all leases are finance

Unlike current accounting and ASC 842, the IASB has chosen to use the finance lease model, with depreciation and interest expense recognized and an inherently front-loaded expense profile, for all leases. However, in addition to the short-term lease exemption that ASC 842 recognizes (for leases with an initial non-cancelable term of 12 months or less), IFRS 16 permits (though doesn’t require) excluding leases of “low value” (the IASB in its deliberations indicated that they considered the threshold to be approximately US$5,000, but that figure is not used in the main text of IFRS 16, only in the Basis for Conclusions). The low value exemption can be invoked on a lease by lease basis; the short-term exemption must be used consistently for all leases in a class of asset (though why anyone would want to capitalize a lease that falls within the short-term definition is not obvious to me).
There are two choices for how to handle the transition for operating leases. This choice must be applied consistently to all lessee leases:


 a)    As with ASC 842, existing operating leases are capitalized as of the beginning of the first comparable period; under IFRS 16, that will usually be one year before the transition date. The initial capitalized value is the present value of the remaining rent payments, using the incremental borrowing rate at the date of initial application as the interest rate. Any deferred rent liability is subtracted from the initial capitalized value to provide the initial gross asset value.
or
b)    The liability is calculated as of the transition date. The asset is either based on the liability at transition, as described in a), or is the carrying amount that would have been recognized had the lease been capitalized from inception. This choice for the asset may be made on a lease-by-lease basis. The primary purpose of this is to reduce the increase in expenses that would otherwise happen switching to the front-loaded finance lease expense model (by setting up an asset less than the liability, with the difference recognized as an adjustment to equity).
If the leased asset is being held as investment property under IAS 40, that standard’s provisions are used to determine the fair value of the asset at each period, and depreciation is not recognized.

Beginning date

IFRS 16 requires implementation for annual reporting periods beginning on or after 1 January 2019. ASC 842 uses December 15, 2018, which means that the required implementation year will differ for entities that have a late December fiscal year end (as can happen for companies that always end their fiscal year on a particular day of the week, for instance). IFRS 16 permits earlier implementation, but implementation cannot be earlier than implementation of IFRS 15, Revenue from Contracts with Customers, also known as RevRec. No separate deadline is provided for nonpublic entities (unlike ASC 842, which gives them an extra year).

Lessor finance leases

ASC 842 recognizes two different types of finance leases for lessors: sales-type and direct financing. IFRS 16 only recognizes a single type. Selling profit therefore can be recognized on a lease that would be considered direct financing by ASC 842.

Variable lease payments

If rents change because of a change to an index or rate, IFRS 16 requires recalculation of the liability based on the new rent, with a corresponding change to the asset. (ASC 842 treats such changes as expensed when incurred, with no impact on the balance sheet, like existing contingent rents.)

Thursday, June 23, 2016

Pushback in Europe?

In the United States, an accounting decision made by the FASB is essentially the end of the process. In Europe, it's not quite so simple. While the IASB is tasked with setting accounting standards, there's still a review role for the European Union (and potentially individual countries' governments). Monitor Daily reports that the European Commission (executive branch of the EU) will review IFRS 16, the IASB's version of the new lease accounting standard, particularly looking at its impact on SMEs (small and medium-sized enterprises). The question is whether the benefits outweigh the costs for smaller organizations that have less sophisticated accounting systems.

From my perspective, the answer is simple: EZ13 is a cost-effective lease accounting system available for both small and large firms! But of course, there are costs beyond the calculation of the lease accounting itself.

Friday, March 18, 2016

Implementation guidance, straight from the source

Both the IASB and the FASB have announced webinars to assist preparers in implementing the new lease accounting standards. The IASB has just posted a web presentation on The Transition to IFRS 16 (focused on transitioning operating leases, and primarily using the cumulative catch-up approach, rather than full retrospective application), along with additional transition/implementation materials available (and soon to be released) shown here.

The FASB will have a webinar on ASC 842 on Tuesday, March 29, 2016, 1-2 PM Eastern time. 1.0 CPE credit hours are offered for CPAs who register. These webinars are typically archived for later viewing, though CPE credit is not available then.

Friday, March 11, 2016

Summary of ASC 842

A nearly 10-year process is complete. The FASB and IASB announced in July 2006 that they would undertake a comprehensive review of lease accounting. the primary purpose was to end the off-balance-sheet status of lessee operating lease accounting, but the boards also wanted to converge their standards, and review other aspects of lease accounting. The original target date for completion was 2009, but it took a Discussion Paper, two Exposure Drafts, over 1700 comment letters, and hundreds of meetings with users and preparers of financial statements, associations of lessees and lessors, accountants, and various other interested parties to finally reach the final document, published by the IASB as IFRS 16 and the FASB as ASC 842. The final result is not converged in some important aspects; most significantly, the IASB has chosen to require all leases to be treated as finance leases, while the FASB is keeping a finance vs. operating distinction for purposes of calculating the expenses (usually recognized straight-line) and asset (equal to the liability for simple leases).

The following is a summary of the most important points, with a particular emphasis on what’s changed from FAS 13. (I will make a later post discussing the significant differences of IFRS 16.)

Lessee operating leases on the balance sheet

All leases with a non-cancelable term of more than 12 months must be capitalized and recognized on the balance sheet (or Statement of Financial Position, to use FASB’s preferred terminology). The liability is calculated as the present value of the remaining rents; the interest rate used is the lease’s implicit rate, if known, otherwise the lessee’s incremental borrowing rate. The asset is calculated starting from the liability, then adjusted by adding any initial direct costs, subtracting lease incentives and impairments, and adding any difference between cash and leveled rent; all these items are amortized straight-line.

What rent is capitalized

The old concept of “executory costs,” which are not capitalized because they don’t reflect recovery of the cost of the asset itself, has been replaced with “nonlease components.” Nonlease components represent payments made which transfer a good or service to the lessee. So charges for a service contract or common area maintenance (CAM) are both executory costs and nonlease components. Charges for taxes and insurance (such as in a gross property lease) are executory costs currently, but do not qualify as nonlease components, and therefore must be included in the capitalized rent.
Land and building leases still qualify for separated treatment, with the land usually not a finance lease. However, the assignment of rent is now proportional to the fair values of the land and building assets, rather than the land rent being calculated based on the incremental borrowing rate.

Classification

While the terminology has changed slightly—FAS 13 capital leases are now called “finance leases,” because all leases are capitalized—the tests to distinguish finance from operating leases are essentially unchanged. While ASC 842-10-25-2 uses “principles” language for the tests (“the lease term is for the major part of the remaining economic life”; “the present value of the … lease payments … equals or exceeds substantially all of the fair value”), 842-10-55-2 says that “one reasonable approach” is to use the 75% and 90% thresholds. We can expect virtually all U.S. preparers to stick with those tried-and-true methods. There is one additional test: “The underlying asset is of such a specialized nature that it is expected to have no alternative use to the lessor at the end of the lease term.” (In such situations, one would expect the lessor to fully recover his investment during the lease, so one of the previous tests would almost certainly be met as well, making the additional test probably insignificant.)

Leases with a non-cancelable term of 12 months or less (including renewal options that are considered reasonably certain of being exercised) may be excluded from capitalization, but their costs (excluding leases with a term of a month or less) must be separately disclosed.
 
Lessors: Leveraged leases have been eliminated (though existing leveraged leases are grandfathered). The distinction between sales-type and direct financing is no longer whether the fair value and carrying amount of the asset are equal, but whether the present value test is met via the rent & residual due from the lessee vs. a third-party guarantee of residual value. A sales-type lease permits immediate recognition of profit; a direct financing lease recognizes the profit from the difference between the fair value and carrying amount though interest income over the life of the lease.

Lessee reporting requirements

Finance leases create an asset and liability, as with current capital leases. The “right of use” asset is depreciated like other PP&E, usually straight line. The liability is amortized using the interest method. Depreciation and interest expense are recognized as currently with capital leases. Accrued interest is immediately booked to the liability account, rather than a separate accrued interest account.
 
Operating leases also create a right-of-use asset and liability, but the liability is called an “operating obligation,” not debt, meaning that it should not be counted as debt for loan covenants and financial ratios. Expenses are recognized in a single lease cost, which is normally straight-line over the lease’s life. For a simple operating lease with the same rent paid for its whole life and no asset adjustments, the net asset and liability are the same at all times. If there are scheduled rent increases, the leveling of rent is recognized as an adjustment to the asset, as are initial direct costs and lease incentives, all of which are amortized straight-line over the lease life.

Finance and operating lease assets and liabilities are reported separately (reflecting their different character; finance lease liabilities typically survive bankruptcy, for instance).
 
Two new disclosures are required: For finance and operating leases separately, the weighted-average remaining lease term (weighted by remaining liability), and the weighted-average discount rate (weighted by remaining lease payments, undiscounted).

Sale-leaseback

Sale-leaseback accounting is permitted only if the “sale” qualifies as a sale under the new Revenue Recognition standard (ASC 606/IFRS 15). This requirement precludes continuing lessee control of the leased asset other than the lease itself; most significantly, if the lessee has a purchase option at a fixed price (rather than fair value at time of exercise), sale-leaseback accounting is not permitted, and the transaction is treated as a financing.

Transition

Implementation is required for fiscal years starting after Dec. 15, 2018, including that year’s interim periods. Private companies may delay until fiscal years starting after Dec. 15, 2019, and need not implement for interim periods until the following year. When implemented, the prior two years must be restated using the new standard, to provide comparable information. Earlier implementation is permitted, but still requires the two-year restatement. (This does not mean refiling prior financial statements, but reporting the prior comparable periods as if the new standard had been in place as of the first comparable period.)

Several “practical expedients” are offered which most lessees are expected to use in transition. On that basis, lease classification is not reassessed; unamortized initial direct costs are carried forward and added to the lease asset without determining whether they qualify as IDC under the new rules. Balances on capital leases are converted to finance lease balances without adjustment (aside from combining accrued interest with liability, and IDC with the asset). Operating leases are set up with the liability equal to the present value of the remaining rents (using the incremental borrowing rate as of the transition date); the asset is the same, adjusted for any unamortized IDC, lease incentives, and deferred rent from leveling scheduled rent increases.

Note that for the two-year lookback period, you will need to retain the data to report leases both ways. In particular, it will be important to record both executory costs and non-lease components of the rent, so that each can be used for the appropriate reporting. 

Proposed changes that were eliminated

The 2010 Exposure Draft called for including all renewal options that were “more likely than not” to be exercised, and for projecting variable lease payments (such as those based on inflation or usage). Vehement disagreement on these proposals led the Boards to remove those proposals.

The 2013 Exposure Draft called for Type A and Type B lease classification based on characteristics of the lease (different rules for real property vs. equipment, in particular). The IASB decided to make all leases finance leases; the FASB decided to return to FAS 13’s classification system.
 
Lessors: The 2010 Exposure Draft called for creation of a Performance Obligation on leases previously considered operating, which would have affected lessor balance sheets. Lessor accounting for operating leases was reinstated virtually unchanged from FAS 13.

We will release later this year an update to our EZ13 lease accounting software which will fully comply with ASC 842. You can use EZ13 right now to forecast the impact of the new standard, because EZ13 includes the ability to treat operating leases as capital on a pro forma basis. For more information about how EZ13 can meet your lease accounting needs, whether you're a lessee or lessor, please check our web site or contact us.

Thursday, February 25, 2016

Media coverage of new lease accounting standard

Several articles have been released discussing the FASB's new lease accounting standard:

New York Times: Post-Enron Accounting Rule Requires Companies to Report Leases

Wall Street Journal: New Rule to Shift Leases Onto Corporate Balance Sheets
Wall Street Journal (CFO blog): A Silver Lining to New Lease Accounting Rules: Savings

Accounting Today: FASB Releases Lease Accounting Standard

CFO: New FASB Lease Standard Could Inflate Balance Sheets
(CFO had a prior article on the complications facing companies that have to report under both US GAAP and IFRS: New Lease Standards May Demand Two Sets of Books)

Journal of Accountancy: New FASB leases standard brings transparency to lessee balance sheets

AccountingWeb: The Wait is Over: FASB Issues New Guidance on Lease Accounting


It's here!

Today (Feb. 25) the Financial Accounting Standards Board (FASB) released ASU 2016-02, the final version of the new lease accounting standard. In the Accounting Standards Codification, this is designated Topic 842 (the prior standard, FAS 13, was designated ASC 840). The release, available on the FASB web site, includes Section A, the main text, at 191 pages; Section B, a mind-numbing description of how the new text changes the existing Topic 840 text (148 pages); and Section C, background information and basis for conclusions (152 pages). This completes a process that started all the way back in July 2006 (and was originally expected to be completed in 2009).

Obviously, I can't look through 350 pages in a morning. There's no reason to expect any major surprises in the text. Illustrations are interspersed throughout the text. As a reminder, the new standard takes effect in 2019 (including interim periods in 2019); U.S. private companies get until year-end 2020 (interim periods don't have to use it until 2021).

To assist with understanding the new standard, the FASB released a Costs and Benefits summary, posted a 6-minute video entitled Why a New Leases Standard?, and announced a webinar for March 29, 1-2 PM EDT (1.0 CPE credit for CPAs).

The International Accounting Standards Board (IASB) released IFRS 16, their new lease accounting standard, on Jan. 12, 2016. Unlike the FASB, the IFRS text is not available for free; eventually the basic text will be released free (without the illustrative examples or basis for conclusions), but at the moment it's only available for purchase individually or as part of an eIFRS Professional Subscription.

I'll have more information in the coming days about the details of the new standard. We are working to complete the updates to EZ13 to meet the requirements of the new standard, including the transition from FAS 13. You can use EZ13 right now to forecast the impact of the new standard, because EZ13 includes the ability to treat operating leases as capital on a pro forma basis. For more information about how EZ13 can meet your lease accounting needs, whether you're a lessee or lessor, please check our web site or contact us.