March 2016
Accounting for Income Taxes: A Year in Review
By Wanda M. Denton, CPA, and Sheryl L. Vander Baan, CPA
Audit | Tax | Advisory | Risk | Performance
. Crowe Horwath LLP
The Financial Accounting Standards Board (FASB) has continued to pursue changes to
accounting standards affecting public and nonpublic entities. Many of these changes
have directly or indirectly affected the financial accounting for income taxes.
Standard Setting Updates
The FASB has been very active of late as part of its Simplification Initiative to reduce
complexity in accounting standards. The initiative is intended to identify, evaluate,
and improve areas of generally accepted accounting principles (GAAP) for which the
cost and complexity can be reduced while maintaining or improving the usefulness
of the information provided for financial statement users. The activity affecting the
accounting for income taxes now, or within the next few years, is summarized below.
Final Standards Issued
â– â– ASU No.
2015-17, “Income Taxes (Topic 740): Balance Sheet Classification of
Deferred Taxes.” The FASB issued ASU 2015-17 on Nov. 20, 2015.
The Accounting Standards Update (ASU) eliminates the current requirement that
entities presenting a classified balance sheet separate deferred tax assets (DTAs)
and deferred tax liabilities (DTLs) into current and noncurrent amounts for each tax
jurisdiction to which the DTAs and DTLs relate. Instead, organizations will be required
to classify DTAs and DTLs as noncurrent for each tax jurisdiction.
The changes apply
to all entities that use a classified balance sheet.
The ASU is effective for public entities for annual periods and related interim
periods beginning after Dec. 15, 2016, and for all other entities for annual periods
beginning after Dec. 15, 2017, and interim periods in the following year.
Early
adoption is permitted for all entities. The revised guidance can be adopted for any
financial statement not yet issued.
Entities can apply the changes prospectively to all DTLs and DTAs or retrospectively
to all periods presented. If an entity opts for prospective application, it should
disclose (in the first interim and first annual period of change) the nature of and
reason for the change in accounting principle and a statement that prior periods
weren’t retrospectively adjusted.
Entities that apply the ASU retrospectively should
disclose, in the first interim and first annual period of change, the nature of and
reason for the change in the accounting principle and quantitative information about
the effects of the accounting change on prior periods.
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A Year in Review
â– â– ASU No. 2015-16, “Business Combinations (Topic 805): Simplifying the
Accounting for Measurement Period Adjustments.” The FASB issued
ASU 2015-16 on Sept. 25, 2015.
The ASU eliminates the requirement to retrospectively account for adjustments
made during the measurement period to provisional amounts recognized in a
business combination. Instead, these adjustments are to be recognized in the
period they are determined.
Furthermore, the effect on earnings related to changes
in depreciation, amortization, and any other resulting income effects are recorded
in the reporting period the adjustments are determined (not retrospectively). This
would include recording the income tax effects on the adjustments, as applicable.
Entities also are required to separately disclose by line item on the face of
the income statement, or in the notes, the portion of the amount recorded in
current period earnings that would have been recorded in previous periods if the
adjustments had been recognized as of the acquisition date.
The ASU is effective for public entities for fiscal years beginning after Dec. 15,
2015, and interim periods within those years.
For all other entities, the ASU is
effective for fiscal years beginning after Dec. 15, 2016, and interim periods within
fiscal years beginning after Dec. 15, 2017.
The ASU must be applied prospectively
to adjustments that occur after its effective date. Early adoption is permitted for
financial statements that have not yet been issued.
Disclosures regarding the nature of and reason for the change in accounting
principle are required in the first annual period of adoption and in the interim
periods within the first annual period of adoption.
Final Update Pending
â– â– Compensation – Stock Compensation (Topic 718): Improvements to
Employee Share-Based Accounting. An exposure draft (ED) was issued on
June 8, 2015, and the board completed redeliberations on Nov.
23, 2015. The
FASB directed its staff to draft a final ASU for vote by written ballot. This ASU
would make multiple changes to the accounting for this compensation.
Only those
changes affecting income tax accounting are discussed below. FASB decisions
are considered tentative until a final ASU is issued.
Currently, if the tax deduction for the vesting or settlement of share-based
compensation exceeds the compensation cost for financial reporting purposes,
the additional tax benefit on the excess amount is recognized in additional paid-in
capital and referred to as an excess tax benefit (sometimes also called a windfall).
The accumulated excess tax benefits can offset current- and subsequent-period
tax deficiencies (shortfalls) when the tax deduction is less than the related financial
reporting compensation cost. If the accumulated excess tax benefit amount is
exhausted, tax deficiencies must be recognized in the income statement.
Finally,
an excess tax benefit cannot be recorded to additional paid-in capital until it is
realized, resulting in a tax refund or otherwise reducing cash taxes payable.
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Selected changes affirmed by the FASB include the following:
Entities would be required to recognize all excess tax benefits and tax
deficiencies in the income statement. The tax effects of windfalls and shortfalls
would be recorded discretely in the period in which they occur. Note: This is a
change from the proposed ASU, which would have required that the tax effects
of windfalls and shortfalls be considered in determining the estimated annual
effective tax rate. This change would be adopted prospectively.
Entities would recognize excess tax benefits in the current period, no longer
having to delay recognition until realized in cash.
This change would be
transitioned to retrospectively, with a cumulative-effect adjustment recognized
in equity. From a disclosure perspective, entities will be required to classify
excess tax benefits in the statement of cash flows as an operating activity,
while classifying the cash paid when directly withholding shares to meet
minimum statutory withholding requirements as a financing activity. The change
in classification of cash paid would be adopted retrospectively, but entities
have the option of adopting the classification of excess tax benefits either
prospectively or retroactively.
The guidance would be effective for public entities for annual periods beginning
after Dec.
15, 2016, including interim periods within those annual periods. For all
other entities, the guidance would be effective for annual periods beginning after
Dec. 15, 2017, and interim periods within annual periods beginning after Dec.
15,
2018. Early adoption would be permitted for all entities.
In the period of adoption, disclosures related to a change in accounting principle
would be required with one exception: Entities would not be required to quantify the
income statement effect of the change (direct or indirect) in the period of adoption.
It should be noted that FASB decisions are considered tentative until the final
ASU is issued. Once the ASU is finalized, entities can adopt the guidance for any
financial statement not yet issued.
Exposure Drafts Issued
â– â– Income Taxes (Topic 740): Intra-entity Asset Transfers.
An exposure draft was
issued on Jan. 22, 2015, and the FASB completed re-deliberations during the fourth
quarter of 2015.
The proposed ASU would eliminate the exception in GAAP that prohibits entities
from recognizing current and deferred income tax consequences for an intra-entity
asset transfer until the asset or assets have been sold to an outside party. Entities
would be required to recognize the consequences when the transfer occurs.
During re-deliberations, the board decided not to affirm the prior decision described
in the exposure draft and directed the staff to perform additional narrowly scoped
research on the costs and benefits of applying the exception only to inventory.
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Accounting for Income Taxes:
A Year in Review
â– â– Disclosures by Business Entities About Government Assistance. An exposure
draft was issued on Nov. 12, 2015, and comments were due by Feb. 10, 2016.
GAAP currently lacks explicit guidance on how to account for government
assistance received by business entities.
The proposed ASU would require
disclosure about 1) the types of arrangements (tax credits, tax exemptions, tax
abatements, loan guarantees, grants, and low-interest or interest-free loans), 2)
the policies for accounting for the government assistance, 3) the effect of the
assistance on the business’s financial statements, and 4) the significant terms and
conditions of the legally enforceable agreement. Specifically, businesses would be
required to make the following disclosures in their annual financial statements:
Information about the nature of the assistance, including a general description
of the significant categories and the related accounting policies adopted or the
method applied to account for government assistance.
Which line items on the balance sheet and income statement are affected by
government assistance and the amounts applicable to each line item.
Significant terms and conditions of the agreement, including commitments and
contingencies.
Unless impracticable, the amount of government assistance received but not
recognized directly in the financial statements. The amount of government
assistance received but not recognized includes value that was received by an
entity for which no amount has been recorded directly in any financial statement
line item (for example, a benefit of a loan guarantee, a benefit of a below-market
rate loan, or a benefit from tax or other expenses that have been abated).
The guidance would apply to all business entities except not-for-profit entities within
the scope of ASC Topic 958.
The guidance would apply to all legally enforceable
agreements under which the government determines whether and to what extent
an entity will receive assistance. It would not apply to transactions in which the
government is the customer or to nondiscretionary benefits that are broadly
available to entities meeting specified eligibility requirements.
“Government” is broadly defined to include domestic, foreign, local, regional, and
national governments as well as governmental entities and intergovernmental
organizations. Because “government” is so broadly defined, the arrangements that
may be subject to the proposed guidance cover a wide range of activities and may
have far-reaching implications to reporting entities.
As currently drafted, there is no scope exception for income tax incentives that
would meet the criteria.
An effective date hasn’t been determined, but the amendments would apply
to all agreements existing at the effective date and those entered into after it.
Retrospective application would be allowed.
FASB decisions are considered tentative until a final ASU is issued.
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In the Pipeline
Income Tax Disclosures
â– â– Foreign earnings. The FASB made tentative board decisions on Feb. 11, 2015, to
require all entities to disclose the following information related to foreign earnings:
Income before taxes disaggregated between domestic and foreign
Further disaggregation of foreign jurisdictions with earnings “significant” to total earnings
Amount of domestic tax expense on foreign earnings recognized in the period
Undistributed foreign earnings for which there is no longer an assertion of indefinite
reinvestment, including separate disclosure of “significant” foreign jurisdictions, along
with an explanation of the circumstances that cause the entity to make that assertion
Disaggregated cumulative amount of foreign earnings for which there is an assertion
of indefinite reinvestment for any country that represents at least 10 percent of the
disclosed amount
â– â– Uncertain tax positions. The FASB made tentative board decisions on Aug.
26, 2015, to
require expanded income tax disclosures related to unrecognized tax benefits as follows:
Enhanced tabular reconciliation to include:
• Bifurcation of settlements using existing tax assets from those settled with cash
• Detail of ending unrecognized tax benefits liability by line item in the balance
sheet in which the liability is recognized
Elimination of the current requirement to disclose positions for which it is reasonably
possible that the unrecognized tax benefit will significantly change within 12 months
of the reporting date
Other disclosures were discussed but not approved
â– â– Effective tax rate reconciliation. The FASB made tentative decisions on Oct. 21, 2015,
to require expanded income tax disclosures related to the effective tax rate
reconciliation as follows:
Tabular reconciliation disclosure for all entities (currently only public entities are
required to include a tabular reconciliation)
Separate disclosure for reconciling items that exceed 5 percent of the amount computed
by multiplying the income before tax by the applicable statutory federal tax rate
Qualitative description of items driving a significant change in the effective tax rate
year-over-year
â– â– Carryforward disclosure requirements.
The FASB made tentative board decisions
on Oct. 21, 2015, to require the following income tax disclosures related to tax attribute
carryforwards for all entities:
Amounts and expiration dates of gross carryforwards recorded on the tax return
Amounts and expiration dates of tax-effected carryforwards that will give rise to a DTA
Total amount of the unrecognized tax benefit that offsets tax-effected carryforwards
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A Year in Review
â– â– Other Disclosures. The FASB made tentative decisions on Oct. 21, 2015, to require
disclosures related to the following:
The enactment of tax law changes if it is probable that the changes will have a
future impact
If deferred taxes are not presented separately on the balance sheet, the line item(s)
in which the amounts are presented
The amount of domestic and foreign income taxes paid
The amount of the valuation allowance recorded and released during the reporting
period, including an explanation of the nature of the change
Staff Research Topics
â– â– Presentation of Tax Expense or Benefit. The FASB is conducting a staff research
project to evaluate the presentation of total tax expense or benefit as a single item on
the income statement.
â– â– Intraperiod Allocations.
The FASB discussed eliminating the exception that exists
within ASC 740-20-45-7 to modify the incremental approach to intraperiod tax
allocation when there are current-year losses from continuing operations. However,
the board would prefer to eliminate intraperiod allocations altogether. The FASB staff
currently is performing additional research and outreach on the topic.
FASB decisions are considered tentative until a final ASU is issued.
Other Standard Updates to Consider
â– â– ASU No.
2013-11, “Income Taxes (Topic 740): Presentation of an Unrecognized
Tax Benefit When a Net Operating Loss Carryforward, a Similar Tax Loss, or a
Tax Credit Carryforward Exists.” The FASB issued ASU 2013-11 on July 18, 2013.
The ASU requires an entity to present an unrecognized tax benefit (or portion thereof)
in the financial statements as a reduction to a DTA for a net operating loss (NOL)
carryforward, a similar tax loss, or a tax credit carryforward. But, to the extent an NOL
carryforward, similar tax loss, or tax credit carryforward isn’t available at the reporting
date under the applicable tax law to settle any additional income taxes that would
result from the disallowance of a tax position – or the applicable tax law doesn’t require
the entity to use, and the entity doesn’t intend to use, the DTA for such purpose – the
unrecognized tax benefit should be presented as a liability and not combined with DTAs.
The ASU is effective for public entities for annual and related interim periods
beginning after Dec. 15, 2013, and for all other entities for annual and related interim
periods beginning after Dec.
15, 2014. The guidance can be adopted for any financial
statement not yet issued.
The amendments are applicable to all unrecognized tax benefits that exist as of the
effective date. Entities have the choice of applying the guidance prospectively or
retrospectively to each prior reporting period presented.
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Contact Information
Wanda Denton is with
Crowe Horwath LLP and can be
reached at +1 630 990 4447 or
wanda.denton@crowehorwath.com.
Sheryl Vander Baan is a
partner with Crowe and can be
reached at +1 616 752 4255 or
sheryl.vanderbaan@crowehorwath.com.
â– â– ASU No. 2014-02, “Intangibles – Goodwill and Other (Topic 350): Accounting for
Goodwill (a Consensus of the Private Company Council).” The FASB issued ASU
2014-02 on Jan. 16, 2014.
The ASU is applicable to all entities other than public business entities and not-forprofit entities. The standard provides private entities with an alternative accounting
model that permits amortization of goodwill on a straight-line basis over 10 years
(or less if supportable).
The alternative accounting model classifies all goodwill
existing at the beginning of the election period as a finite-lived asset. This could have
implications related to valuation allowances, as it may result in taxable temporary
differences that support the realization of deferred tax assets. It should be noted that
the alternative accounting model does not change the prohibition on recording a DTL
for the excess of book over tax goodwill.
The ASU is effective for annual periods beginning after Dec.
15, 2014, and interim periods in
the following year. The guidance can be adopted for any financial statement not yet issued.
â– â– ASU No. 2014-18, “Business Combinations (Topic 805): Accounting for
Identifiable Intangible Assets in a Business Combination (a Consensus of the
Private Company Council).” The FASB issued ASU 2014-18 on Dec.
23, 2014.
The ASU provides an accounting alternative for private entities that acquire identifiable
intangible assets in a business combination. Under the alternative, customer-related
intangible assets that aren’t capable of being sold or licensed independently and
noncompete agreements acquired in a business combination could be subsumed into
goodwill rather than being recognized and amortized as a separately identifiable intangible
asset. Some intangibles, such as commodity supply contracts, customer information, core
deposits, and mortgage servicing rights, still must be recognized separately.
The ASU is effective for annual and related interim periods beginning after Dec.
15, 2015,
or Dec. 15, 2016, depending on the date of the first in-scope transaction and is elected
in conjunction with the goodwill accounting alternative (ASU 2014-02). Early adoption is
permitted.
The guidance can be adopted for any financial statement not yet issued.
Conclusion
Rules affecting the accounting for and reporting of income taxes continue to evolve. It
appears the FASB indeed is simplifying certain aspects of accounting and reporting,
including those related to income taxes. As the accounting standards continue to change,
entities and their tax departments are challenged with not only staying on top of evolving
federal, state, and international tax legislation, but also ensuring proper tax accounting
and disclosures in an ever-shifting environment.
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