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1 Comparison between and International Financial Reporting Standards EDITION 1.5 August 31, 2010

2 Comparison between and International Financial Reporting Standards 2 Contents 1. Introduction... 6 International standards and the IASB... 6 Financial accounting and reporting in the United States... 6 and comparison Overall financial statement presentation General Statement of financial position/balance sheet Statement of comprehensive income/income statement Statement of changes in equity Statement of cash flows Non-current assets held for sale and discontinued operations Accounting policies general Selection of accounting policies Changes in accounting policy and correction of errors Assets Property, plant and equipment Investment property Intangible assets Impairment Inventories Liabilities Leases Provisions, contingent liabilities, and contingent assets Taxation Income and expenditure Revenue - general a Revenue - long-term contracts/construction contracts Employee benefits Share-based payments Financial instruments Recognition and measurement of financial assets Presentation, recognition, and measurement of financial liabilities and equity Recognition and measurement of derivatives Hedge accounting Group accounts Basic requirements for group accounts Noncontrolling interests Special purpose entities/variable interest entities Business combinations Associates, equity method investees, and joint ventures Associates and equity method investees

3 Comparison between and International Financial Reporting Standards Joint ventures Other matters Foreign currency translation Government grants and disclosure of government assistance Earnings per share Events after the reporting period Operating segments Related party disclosures Appendix A Listing of standards Appendix B Listing of FASB Codification Topics Appendix C Listing of post-codification standards (Accounting Standards Updates (ASUs)) Appendix D Listing of pre-codification standards Appendix E Listing of SEC standards Appendix F Listing of other standards This Grant Thornton LLP document provides information and comments on current accounting issues and developments as of August 31, It is not a comprehensive analysis of the subject matter covered and is not intended to provide accounting or other advice with respect to the matters addressed. This document supports Grant Thornton LLP s marketing of professional services, and is not written accounting or tax advice directed at the particular facts and circumstances of any person. If you are interested in the subject of this document we encourage you to contact us or an independent accounting or tax adviser to discuss the potential application to your particular situation. All relevant facts and circumstances, including the pertinent authoritative literature, need to be considered to arrive at conclusions that comply with matters addressed in this document. Moreover, nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this document may be considered to contain written tax advice, any written advice contained in, forwarded with, or attached to this document is not intended by Grant Thornton LLP to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code. For additional information on topics covered in this document, contact your Grant Thornton LLP Adviser.

4 Comparison between and International Financial Reporting Standards 4 Preface Approximately 120 countries require or permit the use of International Financial Reporting Standards () issued by the International Accounting Standards Board (IASB). For many years in the United States, the Securities and Exchange Commission (SEC) required all foreign private issuer (FPI) companies to provide a reconciliation between their home-country required generally accepted accounting principles and. A number of parties had expressed interest in both the removal of the reconciliation requirement for FPIs using and in the acceptance of as a set of high-quality, transparent global accounting standards. In December 2007, the SEC adopted a final rule, Acceptance From Foreign Private Issuers of Financial Statements Prepared in Accordance With International Financial Reporting Standards Without Reconciliation to, allowing FPIs whose financial statements are prepared using as issued by the IASB to file their financial statements without reconciliation to. In September 2002, the Financial Accounting Standards Board (FASB) and the IASB issued a memorandum of understanding (the Norwalk Agreement) wherein they acknowledged their commitment to high-quality, compatible accounting standards that could be used for both domestic and cross-border financial reporting. The memorandum notes that the Boards have pledged to use their best efforts (a) to make their existing financial reporting standards fully compatible as soon as is practicable and (b) to coordinate their future work programs to ensure that once achieved, compatibility is maintained. In February 2006, the Boards issued A Roadmap for Convergence between s and US GAAP ; Memorandum of Understanding between the FASB and the IASB and reaffirmed their commitment to the convergence of and. In September 2008, the Boards issued an update to the 2006 Memorandum of Understanding. The update reports on the progress the Boards have made since 2006 and establishes a goal of completing their major joint projects by In November 2009, the Boards issued a joint statement, FASB and IASB Reaffirm Commitment to Memorandum of Understanding, describing their plans and milestone targets for achieving the goal of completing major joint Memorandum of Understanding projects by the end of June In June 2010, the IASB and FASB announced the issuance of a joint statement on revisions to their convergence work plan. The modified strategy retains the target completion date of June 2011 for many of the projects identified by the original MoU, including those projects, as well as other issues not in the MoU, where a converged solution is urgently required. The target completion dates for a few projects have extended into the second half of It is expected that this action by the IASB and FASB will not negatively impact the Securities and Exchange Commission s work plan, announced in February 2010, to consider in 2011 whether and how to incorporate into the U.S. financial system. In August 2007, the SEC issued a concept release on allowing U.S. issuers to prepare financial statements in accordance with. The comment period closed on November 13, Public roundtables were held at the SEC in December On November 14, 2008, the SEC issued its proposed Roadmap for the Potential Use of Financial Statements Prepared in Accordance with International Financial Reporting Standards by U.S. Issuers (the Roadmap), which could lead to a requirement for U.S. issuers to use as issued by the IASB as early as The proposed Roadmap includes a rule that would permit domestic issuers meeting certain criteria to file financial statements prepared according to beginning with fiscal years ending on or after December 15, The Roadmap proposes

5 Comparison between and International Financial Reporting Standards 5 milestones that the SEC would assess in 2011 in order to determine whether to proceed with rulemaking to mandate the use of by all domestic issuers, including: Improvements in accounting standards Adequate accountability, independence and funding of the International Accounting Standards Committee Foundation Availability of more detailed tagging for interactive reporting Advances in education and training If the SEC proceeds to mandate for all domestic issuers, the Roadmap proposes phased-in adoption dates of 2014, 2015, and 2016, depending on the size of the issuer. At its February 24, 2010 Open Meeting, the SEC approved issuing a statement reaffirming support for convergence of accounting standards, but stated that more information is needed to allow the Commission to make a well-informed decision on whether to incorporate use of International Financial Reporting Standards, as issued by the IASB, by U.S. issuers in its financial reporting system. The SEC staff will develop and execute a work plan to gather information to evaluate and provide further information to the Commission. Although there are many issues that remain to be addressed, many observers believe that the U.S. capital markets will adopt in the not too distant future. In the meantime, given the number of differences that still exist between and, it is incumbent on preparers, auditors, and regulators to be aware of differences between these two sets of standards. We have prepared the Comparison between and International Financial Reporting Standards (Comparison) to help readers identify similarities and differences between and. More emphasis is placed on recognition, measurement, and presentation guidelines and less emphasis is placed on disclosure requirements. As more fully explained in Section 1, Introduction, this Comparison covers only those differences that we believe are more commonly encountered in practice. It includes standards issued up to August 31, The FASB Accounting Standards Codification was launched on July 1, 2009 (see further explanation of the FASB Codification in the Introduction below). The references in this document include citations from both pre-codification literature and their Codification counterparts. We have included Appendices that list the titles of all,, and SEC standards that are referred to in this document.

6 Comparison between and International Financial Reporting Standards 6 1. Introduction International standards and the IASB The IASB is responsible for the preparation and issuance of International Financial Reporting Standards (). Upon its inception in 2001, the IASB adopted the body of International Accounting Standards (IAS) issued by its predecessor, the International Accounting Standards Committee (IASC). The Interpretations Committee (IFRIC) assists the IASB in establishing and improving standards of financial accounting and reporting for the benefit of users, preparers, and auditors of financial statements. IFRIC was established in 2002 when it replaced its predecessor the Standing Interpretations Committee (SIC). Under, when a standard or interpretation specifically applies to a transaction, other event or condition, the accounting policy or policies applied to that item is determined by applying the standard or interpretation and considering any relevant implementation guidance issued by the IASB. In this document, refers collectively to International Financial Reporting Standards issued by the IASB, International Accounting Standards issued by the IASC, and Interpretations issued by the IFRIC and the SIC. Financial accounting and reporting in the United States The FASB is the designated private sector body responsible for establishing and improving standards of financial accounting and reporting in the United States for non-governmental public and private enterprises, including small businesses and not-for-profit organizations. Those standards, which govern the preparation of financial reports, are provided for the guidance and education of the public, including issuers, auditors and users of financial information. In certain cases, financial accounting and reporting requirements in the United States had been derived from U.S. Generally Accepted Auditing Standards (GAAS), as well as ethics requirements established by the American Institute of Certified Public Accountants (AICPA). The AU reference in this Comparison refers to GAAS promulgated by the AICPA. On July 1, 2009, the structure of changed dramatically with the launch of the FASB Accounting Standards Codification (Codification). On June 30, 2009, the FASB issued ASC 105 (SFAS 168), The FASB Accounting Standards Codification and the Hierarchy of Generally Accepted Accounting Principles (Codification), to establish the Codification as the sole source of authoritative nongovernmental GAAP, except for SEC guidance. ASC 105 (SFAS 168) replaces the four-tiered hierarchy described in SFAS 162, The Hierarchy of Generally Accepted Accounting Principles, with a two-level hierarchy consisting only of authoritative and nonauthoritative guidance. ASC 105 (SFAS 168) is effective for financial statements issued for interim and annual periods ending after September 15, 2009, except for nonpublic, nongovernmental entities that have not followed the guidance in paragraphs 38 through 76 of AICPA Technical Inquiry Service section 5100, Revenue Recognition. That guidance must be adopted for fiscal years beginning on or after December 15, 2009 and for interim periods within those years. The Codification does not create new accounting or reporting guidance. The FASB developed the Codification in response to constituents reported difficulties with applying guidance under the four-tiered GAAP hierarchy. To address those concerns, the FASB designed the Codification to simplify the application of by consolidating all authoritative guidance in a single document and by rewriting the guidance using a consistent

7 Comparison between and International Financial Reporting Standards 7 organizational structure. The FASB launched the Codification after a one-year trial period during which constituents provided feedback. SEC registrants must also comply with U.S. Securities and Exchange Commission financial reporting requirements including those promulgated in SEC Regulations S-X and S-K, Financial Reporting Releases (FRR), and Staff Accounting Bulletins (SAB). The SABs represent practices followed by the staff in administering SEC disclosure requirements. and comparison This Comparison highlights some of the more significant and requirements as well as the major similarities and differences between current and. While not an exhaustive listing, we highlight some of the more significant differences between and that we believe are most commonly encountered in practice, which should assist those new to in gaining an appreciation of their major requirements and how these differ from requirements in the United States. Disclosure requirements are not addressed except in exceptional cases where those requirements constitute major differences between U.S. GAAP and. Companies reporting according to requirements established for the EU comply with as adopted by the European Commission. Those standards may differ from as issued by the IASB because of the timing or scope of endorsement by the EC. Other jurisdictions may have similar endorsement related differences. Such differences are not addressed in this document. This Comparison has been updated for standards issued through August 31, Effective dates for standards vary and are generally noted where relevant. This Comparison does not address industry-specific requirements for banks, other financial institutions, insurance companies, not-for-profit organizations, retirement benefit plans, extractive industries, or agriculture. In particular, the following pronouncements have not been included in the document due to their specialized nature: 4, Insurance Contracts 6, Exploration for and Evaluation of Mineral Resources IAS 26, Accounting and Reporting by Retirement Benefit Plans IAS 41, Agriculture Each year the IASB considers minor amendments to in an annual improvements project. The amendments represent non-urgent but necessary amendments to and are proposed each year in an omnibus Exposure Draft. The IASB has issued Annual Improvements for 2010 which are included in this Comparison where applicable. This Comparison also does not include standards that address first-time adoption of and for small and medium-sized companies:

8 Comparison between and International Financial Reporting Standards 8 In November 2008, the IASB issued a revised 1, First-time Adoption of International Financial Reporting Standards, which is effective for reporting periods beginning on or after July 1, 2009 with earlier application permitted. 1 covers the application of in a company's first financial statements. It starts with the basic premise that an entity applies for the first time on a fully retrospective basis. However, acknowledging the cost and complexity of that approach, it then establishes various exemptions for topics where retrospective application would be too burdensome or impractical (e.g. business combinations and pension liabilities.) In planning the conversion, management must develop a detailed and specific understanding of 1's implications on their business. In July 2009, the IASB issued International Financial Reporting Standard for Small and Medium-sized Entities ( for SMEs). for SMEs is designed to meet the financial reporting needs of entities that (a) do not have public accountability and (b) publish general purpose financial statements for external users. The term Small and Medium-sized Entities is not associated with any size criteria in the Standard. The Standard has essentially been designed to work as a standalone document, with no mandatory cross references to full. for SMEs often permits simplified recognition and measurement and reduces the amount of disclosure required, compared to full. Also, in November 2009, the IASB issued 9, Financial Instruments. Entities are required to apply 9 for annual periods beginning on or after January 1, Earlier application is permitted. Note that this document does not include 9. 9 Appendix C includes the amendments to other resulting from 9. Those are as follows: 1, First-time Adoption of International Financial Reporting Standards 3, Business Combinations 4, Insurance Contracts 5, Non-Current Assets Held for Sale and Discontinued Operations 7, Financial Instruments: Disclosures IAS 1, Presentation of Financial Statements IAS 2, Inventories IAS 8, Accounting Policies, Changes in Accounting Estimates and Errors IAS 12, Income Taxes IAS 18, Revenue IAS 21, The Effects of Changes in Foreign Exchange Rates

9 Comparison between and International Financial Reporting Standards 9 IAS 27, Consolidated and Separate Financial Statements IAS 28, Investments in Associates IAS 31, Interests in Joint Ventures IAS 32, Financial Instruments: Presentation IAS 36, Impairment of Assets IAS 39, Financial Instruments: Recognition and Measurement IFRIC 10, Interim Financial Reporting and Impairment IFRIC 12, Service Concession Arrangements This Comparison is only a guide; for the complete details of and requirements, readers should refer to the text of the standards themselves.

10 Comparison between and International Financial Reporting Standards Overall financial statement presentation Note: and provide only limited financial statement presentation guidance. In addition, presentation guidelines in are dispersed across the standards. Moreover, users of financial statements have often expressed dissatisfaction that information is not linked across the different statements and that dissimilar items are in some cases aggregated in one number. The objective of the IASB/FASB joint financial statement presentation project is to establish a global standard that will guide the organization and presentation of information in the financial statements. The Boards goal is to improve the usefulness of the financial information provided in an entity s financial statements to assist management to better communicate its financial information to the users of its financial statements, and to help users in their decision making. In October 2008, the IASB and the FASB (the Boards) jointly announced the issuance of their Discussion Papers on the presentation of financial statements. The Discussion Paper, Preliminary Views on Financial Statement Presentation, is an analysis of current issues in financial statement presentation and proposed responses to those issues by the Boards. The objective of the Discussion Paper is to invite comments on a new format for financial statements designed to communicate information to users following three new principles: cohesiveness, disaggregation, and liquidity/financial flexibility. The staffs of the IASB and FASB also issued Snapshot: Preliminary Views on Financial Statement Presentation, a summary of the major ideas presented in the Discussion Papers. In June 2010, the Boards decided to engage in additional outreach activities before finalizing and publishing an exposure draft on financial statement presentation. Those activities will focus primarily on two areas: (1) the perceived benefits and costs of the proposals and (2) the implications of the proposals for financial reporting by financial services entities. In July 2010, the staff of the IASB and the FASB posted on each Board s website a Staff Draft of an exposure draft that reflects the Boards cumulative tentative decisions on financial statement presentation, through their joint meeting in April The proposals in that Staff Draft are the basis for the staff outreach activities. As noted in the introduction and summary that accompanied the staff draft, the Boards are not formally inviting comments on the staff draft; however, they welcome input from interested parties. 2.1 General Relevant guidance: IAS 1 Note: Additional requirements may be specified by local statute, regulators, or stock exchanges. An entity shall apply IAS 1 in preparing and presenting general purpose financial statements in accordance with (IAS 1.2). IAS also apply to condensed interim financial statements (IAS 1.4). General purpose financial statements (referred to as financial statements ) are those intended to meet the needs of users who are not in a position to require an entity to prepare reports tailored to their particular information needs (IAS 1.7). A complete set of financial statements comprises Relevant guidance: Form and content specified by GAAP as set forth in FASB Accounting Standards Codification (ASC) 205, 220, 505 (GAAP Hierarchy in SFAS 162) and SEC Regulation S-X, Rules 3-01(a) and 3-02(a). (Also, SFAS 130; APB 12; ARB 43). Financial statements comprise:

11 Comparison between and International Financial Reporting Standards 11 (IAS 1.10): A statement of financial position as at the end of the period A statement of comprehensive income for the period. As permitted by IAS 1.81, an entity may present the components of profit or loss either as part of a single statement of comprehensive income or in a separate income statement. When an income statement is presented it is part of a complete set of financial statements and shall be displayed immediately before the statement of comprehensive income (IAS 1.12). A statement of changes in equity for the period A statement of cash flows for the period Notes, comprising a summary of significant accounting policies and other explanatory information A statement of financial position as at the beginning of the earliest comparative period when an entity applies an accounting policy retrospectively or makes a retrospective restatement of items in its financial statements, or when it reclassifies items in its financial statements An entity may use titles for the statements other than those used in IAS 1 (IAS 1.10). An entity shall present with equal prominence all of the financial statements in a complete set of financial statements (IAS 1.11). Except when permit or require otherwise, an entity shall disclose comparative information in respect of the previous period for all amounts reported in the current period s financial statements. An entity shall include comparative information for narrative and descriptive information when it is relevant to an understanding of the current period s financial statements (IAS 1.38). An entity whose financial statements comply with shall make an explicit and unreserved statement of such compliance in the notes. An entity shall not describe financial statements as complying with unless they comply with all the requirements of (IAS 1.16). An entity cannot rectify inappropriate accounting policies by disclosure of the accounting policies used or by notes or explanatory material (IAS 1.18). An entity shall clearly identify each financial statement Balance sheet Income statement A statement of comprehensive income. This statement may be reported separately or combined with the income statement or the statement of changes in stockholders equity (ASC ) (SFAS ) Statement of changes in stockholders equity. Alternatively, disclosure of changes in the separate accounts comprising stockholders equity (in addition to retained earnings) could be made in the notes to financial statements (ASC ) (APB 12.10) Statement of cash flows (limited exemptions; see Section 2.5, Statement of cash flows ) Notes to financial statements Unlike, does not have a similar requirement for a third balance sheet Unlike, under there is no specific requirement to provide comparative statements but it is desirable to do so (ASC ) (ARB 43, Ch. 2A, par. 2). SEC rules require balance sheets for the two most recent fiscal years and three year statements of income and cash flows (SEC Regulation S-X; Rules 3-01(a) and 3-02(a)). Unlike, does not have a similar requirement. Similar to. Similar to.

12 Comparison between and International Financial Reporting Standards 12 and the notes. In addition, an entity shall display the following information prominently, and repeat it when necessary for the information presented to be understandable (IAS 1.51): The name of the reporting entity or other means of identification, and any change in that information from the end of the preceding reporting period Whether the financial statements are of an individual entity or a group of entities The date of the end of the reporting period or the period covered by the set of financial statements or notes The presentation currency; as defined in IAS 21 The level of rounding used in presenting amounts in the financial statements 2.2 Statement of financial position/balance sheet Relevant guidance: IAS 1 Relevant guidance: ASC 210, 215, 470, 505, and 740; (ARB 43; SFAS 6, 47, 78 and 109; FIN 39; APB 12; EITF D-43) SEC Regulation S-X, Rule 5-02 IAS 1 specifies items that must be presented on the face of the statement of financial position, and lists additional information that must be either on the face or in the notes (IAS ). At a minimum, the statement of financial position shall include line items that present the following amounts (IAS 1.54): Property, plant and equipment Investment property Intangible assets Financial assets (excluding amounts shown under investments accounted for using the equity method; trade and other receivables; and cash and cash equivalents) Investments accounted for using the equity method Biological assets Inventories Trade and other receivables Cash and cash equivalents The total of assets classified as held for sale and assets included in disposal groups classified as Unlike, does not prescribe a standard format. SEC Regulation S-X, Rule 5-02 does require specific line items to appear on the face of the balance sheet, where applicable.

13 Comparison between and International Financial Reporting Standards 13 held for sale in accordance with 5 Trade and other payables Provisions Financial liabilities (excluding amounts shown under trade and other payables; and provisions) Liabilities and assets for current tax, as defined in IAS 12 Deferred tax liabilities and deferred tax assets, as defined in IAS 12 Liabilities included in disposal groups classified as held for sale in accordance with 5 Non-controlling interests, presented within equity Issued capital and reserves attributable to owners of the parent An entity shall present additional line items, headings and subtotals in the statement of financial position when such presentation is relevant to an understanding of the entity s financial position (IAS 1.55). An entity shall present current and non-current assets, and current and non-current liabilities, as separate classifications in its statement of financial position in accordance with IAS , except when a presentation based on liquidity provides information that is reliable and more relevant. When that exception applies, an entity shall present all assets and liabilities in order of liquidity (IAS 1.60). No subtotals are specified in IAS 1. Similar to. The balance sheets of most enterprises show separate classifications of current assets and liabilities (ASC ). However, unlike, an unclassified balance sheet is commonplace for enterprises in specialized industries for which the distinction is deemed to have little or no relevance (ASC ) (SFAS 6.7). Unlike, non-sec reporting entities are required by ASC (SFAS 6.15) to present a total of current liabilities if they present a classified balance sheet. As a matter of practice, these non-sec reporting entities also present a subtotal for current assets as well. SEC rules explicitly require subtotals for current assets and current liabilities (Regulation S-X, Rule 5-02). When an entity presents current and non-current assets, and current and non-current liabilities, as separate classifications in its statement of financial position, it shall not classify deferred tax assets (liabilities) as current assets (liabilities) (IAS 1.56). An entity shall classify an asset as current when (IAS 1.66): It expects to realise the asset, or intends to sell or consume it, in its normal operating cycle. The normal operating cycle where not clearly identifiable is assumed to be 12 months (IAS 1.68). Unlike, deferred tax assets and liabilities are separated into current and non-current amounts and the net current deferred tax asset or liability and the net noncurrent deferred tax asset or liability, if any, is shown on the face of the balance sheet (ASC ) (SFAS ). Current assets are cash and other assets or resources commonly identified as those which are reasonably expected to be realized in cash or sold or consumed during the normal operating cycle of the business (ASC Master Glossary, Current Assets ) (ARB 43, Ch. 3A.4). In businesses where the period of the operating cycle is

14 Comparison between and International Financial Reporting Standards 14 It holds the asset primarily for the purpose of trading It expects to realise the asset within 12 months after the reporting period more than 12 months, the longer period should be used. Where a particular business has no clearly defined operating cycle, the one-year rule governs (ASC ) (ARB 43, Ch. 3A.5). The asset is cash or a cash equivalent (as defined in IAS 7) unless the asset is restricted from being exchanged or used to settle a liability for at least 12 months after the reporting period An entity shall classify all other assets as non-current (IAS 1.66). An entity shall classify a liability as current when (IAS 1.69): It expects to settle the liability in its normal operating cycle. The normal operating cycle where not clearly identifiable is assumed to be 12 months (IAS 1.70). Current liabilities are obligations whose liquidation is reasonably expected to require the use of existing resources properly classifiable as current assets, or the creation of other current liabilities (ASC Master Glossary, Current Liabilities ) (ARB 43, Ch. 3A.7). It holds the liability primarily for the purpose of trading The liability is due to be settled within 12 months after the reporting period The entity does not have an unconditional right to defer settlement of the liability for at least 12 months after the reporting period An entity shall classify all other liabilities as non-current (IAS 1.69). An entity classifies its financial liabilities as current when they are due to be settled within 12 months after the reporting period, even if (IAS 1.72(b)): The original term was for a period longer than 12 months, and An agreement to refinance, or to reschedule payments, on a long-term basis is completed after the reporting period and before the financial statements are authorised for issue Unlike, short-term obligations, other than those arising from transactions in the normal course of business that are due in customary terms, are excluded from current liabilities only if the entity intends to refinance the obligation on a long-term basis and (ASC ) (SFAS ): Before the balance sheet is issued there is a postbalance sheet issuance of a long-term obligation or equity securities for the purpose of refinancing the obligation on a long-term basis; or Before the balance sheet is issued the entity has entered into a financing agreement that permits it to refinance the short-term obligation on a long-term basis and certain conditions are met When an entity breaches a provision of a long-term loan arrangement on or before the end of the reporting period with the effect that the liability becomes payable on demand, it classifies the liability as current, even if the lender has agreed, after the reporting period and before authorisation of the financial statements for issue, not to demand payment as a consequence of the Unlike, an entity must classify as current a long-term obligation that is or will be callable by a creditor because of the entity s violation of a provision of the debt agreement at the balance sheet date or because the violation, if not cured within a specified grace period, will make the obligation callable unless (ASC ) (SFAS 78.5):

15 Comparison between and International Financial Reporting Standards 15 breach. An entity classifies the liability as current because, at the end of the reporting period, it does not have an unconditional right to defer its settlement for at least 12 months after that date (IAS 1.74). The creditor has waived or subsequently lost the right to demand repayment for more than one year (or operating cycle, if longer) from the balance sheet date; or For long-term obligations containing a grace period within which the entity may cure the violation, it is probable that the violation will be cured within that period An entity shall disclose the amount expected to be recovered or settled after more than 12 months for each asset and liability line item that combines amounts expected to be recovered or settled (IAS 1.61): No more than 12 months after the reporting date, and ASC (SFAS 47.10) requires that the combined aggregate amount of maturities and sinking fund requirements for all long-term borrowings be disclosed for each of the five years following the date of the latest balance sheet presented. More than 12 months after the reporting period An entity shall not offset assets and liabilities or income and expenses, unless required or permitted by an (IAS 1.32). Unlike, offsetting is permitted only when (ASC ) (FIN and EITF Topic D-43): The parties owe each other determinable amounts There is a right and intention to set-off The right of set-off is enforceable by law An entity shall disclose, either in the statement of financial position or in the notes, further subclassifications of the line items presented, classified in a manner appropriate to the entity s operations (IAS 1.77). An entity shall disclose the following, either in the statement of financial position or the statement of changes in equity, or in the notes (IAS 1.79): For each class of share capital: The number of shares authorised Similar to. Disclosure of changes in the separate accounts comprising stockholders' equity (in addition to retained earnings) is required. These disclosures may be made in the notes to the financial statements or through a separate financial statement (ASC ) (APB 12.10). The number of shares issued and fully paid, and issued but not fully paid Par value per share, or that the shares have no par value A reconciliation of the number of shares outstanding at the beginning and at the end of the period The rights, preferences and restrictions attaching to that class including restrictions on the distributions of dividends and the repayment of capital Shares in the entity held by the entity or by its subsidiaries or associates

16 Comparison between and International Financial Reporting Standards 16 Shares reserved for issue under options and contracts for the sale of shares, including terms and amounts A description of the nature and purpose of each reserve within equity 2.3 Statement of comprehensive income/income statement Note: Current and allow reporting entities several alternatives for displaying other comprehensive income and its components in financial statements. Accordingly, the IASB and the FASB (the Boards) decided to have a separate joint project on the presentation of other comprehensive income in order to converge the requirements. In May 2010 the Boards issued separate exposure drafts with consistent proposed requirements. The IASB Exposure Draft, Presentation of Items of Other Comprehensive Income, proposes that entities present profit or loss and other comprehensive income in separate sections of a continuous statement. The IASB is also proposing to group items in other comprehensive income on the basis of whether they will eventually be recycled into the profit or loss section of the income statement. The comment period ends September 30, The FASB s proposed Accounting Standards Update, Statement of Comprehensive Income also proposes that entities present profit or loss and other comprehensive income in separate sections of a continuous statement. The amendments in the proposed ASU would not change the items that must be reported in other comprehensive income or when an item of other comprehensive income must be reclassified to net income. The comment period ends September 30, Although the Boards agree on how items of comprehensive income should be reported, other differences between U.S. GAAP and will remain that affect the comparability of financial statements prepared under and. In particular, there are differences between some types of items reported in other comprehensive income and the requirements for reclassifying those items into net income. Relevant guidance: IAS 1; 5 Relevant guidance: ASC 220, 225, 320, 715, and 810 (ARB 43; SFAS 130, 144, and 160; APB 12 and 30) SEC Regulation S-X, Rule 5-03 An entity shall present all items of income and expense recognised in a period (IAS 1.81): In a single statement of comprehensive income, or In two statements: A statement displaying components of profit or loss (separate income statement), and A statement beginning with profit or loss and displaying components of other comprehensive income (statement of comprehensive income) The purpose of reporting comprehensive income is to report a measure of all changes in equity of an enterprise that result from recognized transactions and other economic events of the period other than transactions with owners in their capacity as owners (ASC ) (SFAS ). Comprehensive income and its components must be displayed in a financial statement that is displayed with the same prominence as the other financial statements that constitute a full set of financial statements. A specific format is not required but net income must be displayed as a component of comprehensive income in the financial statement that displays the comprehensive income information. Comprehensive income may be displayed As part of the income statement, On a stand-alone basis, or

17 Comparison between and International Financial Reporting Standards 17 At a minimum, the statement of comprehensive income shall include line items that present the following amounts for the period (IAS 1.82): Revenue Finance costs Share of the profit or loss of associates and joint ventures accounted for using the equity method Tax expense A single amount comprising the total of: The post-tax profit or loss of discontinued operations, and The post-tax gain or loss recognised on the measurement to fair value less costs to sell or on the disposal of the assets or disposal group(s) constituting the discontinued operations Profit or loss Each component of other comprehensive income classified by nature (excluding amounts in the share of other comprehensive income of associates and joint ventures accounted for using the equity method) Share of the other comprehensive income of associates and joint ventures accounted for using the equity method Total comprehensive income Reclassification adjustments An entity may present reclassification adjustments relating to components of other comprehensive income in the statement of comprehensive income or in the notes (IAS 1.94). Other comprehensive income income tax An entity may present components of other comprehensive income either (a) net of related tax effects, or (b) before related tax effects with one amount shown for the aggregate amount of income tax relating to those components (IAS 1.91). An entity shall disclose the following items in the statement of comprehensive income as allocations for the period (IAS 1.83): Profit or loss for the period attributable to: As part of the statement of changes in stockholders equity (ASC through 45-9) (SFAS ) ASC 220 (SFAS 130) divides comprehensive income into net income and other comprehensive income. An enterprise shall continue to display an amount for net income. An enterprise that has no items of other comprehensive income in any period presented is not required to report comprehensive income (ASC ) (SFAS ). Classifications within net income Items included in net income are displayed in various classifications. Those classifications can include income from continuing operations, discontinued operations, extraordinary items, and cumulative effects of changes in accounting principle. ASC 220 (SFAS 130) does not change those classifications or other requirements for reporting results of operations (ASC ) (SFAS ). Classifications within other comprehensive income Items included in other comprehensive income shall be classified based on their nature. For example, under existing accounting standards, other comprehensive income shall be classified separately into foreign currency items, gains or losses associated with pension or other postretirement benefits, prior service costs or credits associated with pension or other postretirement benefits, transition assets or obligations associated with pension or other postretirement benefits, and unrealized gains and losses on certain investments in debt and equity securities. Additional classifications or additional items within current classifications may result from future accounting standards (ASC ) (SFAS ). Reclassification adjustments Adjustments shall be made to avoid double counting in comprehensive income items that are displayed as part of net income for a period that also had been displayed as part of other comprehensive income in that period or earlier periods (ASC ) (SFAS ). Other comprehensive income income tax Similar to (ASC ) (SFAS ). All components of comprehensive income shall be reported in the financial statements in the period in which they are recognized. A total amount for comprehensive income shall be displayed in the financial statement where the components of other comprehensive income are

18 Comparison between and International Financial Reporting Standards 18 Non-controlling interests Owners of the parent Total comprehensive income for the period attributable to: Non-controlling interests Owners of the parent An entity may present in a separate income statement the line items in IAS 82(a)-(f) and the disclosures in IAS 1.83(a) (IAS 1.84). An entity shall not present any items of income or expense as extraordinary items, in the statement of comprehensive income or the separate income statement (if presented), or in the notes (IAS 1.87). When items of income or expense are material, an entity shall disclose the amount and nature of those items either in the statement of comprehensive income or in the notes (IAS 1.97). Additional line items, headings and subtotals are presented where relevant to an understanding of financial performance (IAS 1.85). For financial instruments (see Section 7) and investment property (see Section 4.2), some unrealised gains from fair value adjustments are included in the income statement. In, there are instances where gains or losses initially recognised in equity are reclassified to the income statement on subsequent realisation (e.g. available-for-sale investments, foreign exchange losses on net investment in subsidiaries, and hedged items). reported. In accordance with ASC A (ARB 51.38(a), as amended by SFAS 160), if an entity has an outstanding noncontrolling interest (minority interest), amounts for both comprehensive income attributable to the parent and comprehensive income attributable to the noncontrolling interest in a less-thanwholly-owned subsidiary are reported on the face of the financial statement in which comprehensive income is presented in addition to presenting consolidated comprehensive income (ASC ) (SFAS ). Unlike, does not prescribe a standard format; the single-step format or multiple-step format is acceptable. SEC Regulation S-X, Rule 5-03 does require specific line items to appear on the face of the income statement, where applicable. Unlike, defines extraordinary items as material items that are both unusual and infrequently occurring (ASC ) (APB 30.20). Extraordinary items are rare. A material event or transaction that is unusual in nature or occurs infrequently but not both should be reported as a separate component of income from continuing operations (ASC ) (APB 30.26). Under ASC 320 (SFAS 115) (see Section 7, Financial instruments ), unrealized gains and losses on investments in certain debt and equity securities classified as trading are recognized as fair value adjustments through the income statement. Further, since follows a cost model for investment property (see Section 4.2, Investment property ), unrealized gains on investment property are not recognized while losses on impairment of long-term assets to be held and used (see Section 4.4, Impairment ) are recognized and included in the income statement. Similar to. See Section 7.1, Recognition and measurement of financial assets and Section 10.1, Foreign currency translation. Amounts related to pension and other postretirement benefit plans that are initially recognized in other comprehensive income are also reclassified according to the recognition provisions of ASC 715 (SFAS 87, 88, and 106).

19 Comparison between and International Financial Reporting Standards Statement of changes in equity Relevant guidance: IAS 1 Relevant guidance: ASC 810 (SFAS 160) An entity shall present a statement of changes in equity showing in the statement (IAS 1.106): Total comprehensive income for the period, showing separately the total amounts attributable to owners of the parent and to non-controlling interests For each component of equity, the effects of retrospective application or retrospective restatement recognised in accordance with IAS 8 For each component of equity, a reconciliation between the carrying amount at the beginning and the end of the period, separately disclosing changes resulting from: Profit or loss An entity shall disclose for each reporting period either in the consolidated statement of changes in equity, if presented, or in the notes to consolidated financial statements, a reconciliation at the beginning and the end of the period of the carrying amount of total equity, equity attributable to the parent, and equity attributable to the noncontrolling interest. That reconciliation shall separately disclose (see ASC G through 55-4L (SFAS 160.A7) (ASC A) (SFAS c): Net income Each component of other comprehensive income Transactions with owners acting in their capacity as owners, showing separately contributions from and distributions to owners Each item of other comprehensive income Transactions with owners in their capacity as owners, showing separately contributions by and distributions to owners and changes in ownership interests in subsidiaries that do not result in a loss of control An entity shall present, either in the statement of changes in equity or in the notes, the amount of dividends recognised as distributions to owners during the period, and the amount per share (IAS 1.107). 2.5 Statement of cash flows Relevant guidance: IAS 7; 5 Relevant guidance: ASC 230 and 830 (SFAS 95,102, and 104) There are no exemptions under for providing a statement of cash flows. Cash comprises cash on hand and demand deposits (IAS 7.6). Cash equivalents are short-term, highly liquid Unlike, provides an exemption for providing a statement of cash flows as follows (ASC ) (SFAS ): Defined benefit pension plans and certain other employee benefit plans Highly liquid investment companies that meet specified criteria The statement of cash flows shows changes in cash and cash equivalents (i.e. short-term, highly liquid investments that are readily convertible to known amounts of cash and

20 Comparison between and International Financial Reporting Standards 20 investments that are readily convertible to known amounts of cash and which are subject to an insignificant risk of changes in value (IAS 7.6). An investment normally qualifies as a cash equivalent only when it has a short maturity of, say, three months or less from the date of acquisition (IAS 7.7). Bank borrowings are generally considered to be financing activities. However, in some countries, bank overdrafts which are repayable on demand form an integral part of an entity's cash management. In these circumstances, bank overdrafts are included as a component of cash and cash equivalents. A characteristic of such banking arrangements is that the bank balance often fluctuates from being positive to overdrawn (IAS 7.8). The statement of cash flows shall report cash flows during the period classified by the following (IAS 7.10): so near their maturity that they present insignificant risk of changes in value because of changes in interest rates.) Generally, only investments with original maturities of three months or less are cash equivalents (ASC Master Glossary, Cash Equivalents ) (SFAS ). Unlike, bank overdrafts are included in liabilities and excluded from cash equivalents. Changes in overdraft balances are financing activities. Similar to (ASC ) (SFAS 95.14). Operating activities Investing activities Financing activities IAS 7.18 allows the cash flows from operating activities to be disclosed by either the direct method (i.e. major classes of gross cash receipts and cash payments are disclosed) or the indirect method (i.e. profit or loss is adjusted for the effects of transactions of a non-cash nature, any deferrals or accruals of past or future operating cash receipts or payments, and items of income or expense associated with investing or financing cash flows) ASC 230 (SFAS 95) allows either the direct or indirect method but in any case requires that the financial statement presentation include a reconciliation of net cash flow from operating activities to net income. If the indirect method is used, interest paid (net of amounts capitalized) and income taxes paid must be disclosed (ASC through and 50-2) (SFAS ). IAS 7.20 provides for two alternative presentations for the indirect method. Cash flows arising from the following operating, investing or financing activities may be reported on a net basis (IAS 7.22): Cash receipts and payments on behalf of customers when the cash flows reflect the activities of the customer rather than those of the entity Cash receipts and payments for items in which the turnover is quick, the amounts are large, and the maturities are short Cash flows from interest and dividends received and paid shall each be disclosed separately. Each shall be classified in a consistent manner from period to period as either operating, investing, or financing activities Receipts and payments should generally be shown gross. Certain items may be presented net because their turnover is quick, the amounts are large, and the maturities are short. Items that qualify for net reporting are cash flows pertaining to (a) investments (other than cash equivalents), (b) loans receivable, and (c) debt, provided that the original maturity of the asset or liability is three months or less (ASC through 45-9) (SFAS ). Interest and dividends received and interest paid are classified as operating activities. Dividends paid are classified as financing activities (ASC through 45-17) (SFAS ).

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