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PRACTICE ALERT

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While SEC comments pertain to public entities, their comments can provide valuable practice pointers for nonpublic entity financial statement preparers. In the areas covered in this Topic, the SEC has commented in recent years that preparers should consider carefully:

 Why current earnings before taxes and depreciation are not comparable to the corresponding prior period measures due to the reclassifications of devices from inventory to property, plant, and equipment and the lack of inclusion of periodic depreciation expenses related to equipment leasing revenue.

 Whether the operations they have disposed of meet the criteria to be accounted for as discontinued operations.

 Whether the discontinued operations meet the criteria for classification as a component or group of components of an entity, or an entity that represents a strategic shift that will have a major effect on the entity's operations and financial results and meets the other criteria in ASC 205‐20‐45‐1B.

 Whether the assets classified as held for use meet the criteria in ASC 360.

 Why the entity's expected sale of a component is not reflected as held for sale and discontinued operations.

 Whether assets held for sale or disposal were tested for impairment in prior periods or in the current period.

 The factors used to present, or not present, assets held for sale separately on the statement of financial position,.

 The timeline of events leading to an asset sale.

 Why gain or loss on a sale of the disposition is not disclosed.

 Known trends, events, or uncertainties that are reasonably likely to impact future liquidity and/or going concern.

Preparers would be prudent to document their conclusions on any of the above items.

Wiley GAAP: Financial Statement Disclosure Manual

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