Undistributed foreign earnings that are indefinitely reinvested outside the United States result in a significant unrecorded tax liability for many U.S.-based multinationals. The amount of undistributed foreign earnings has grown substantially in recent years. As a result, expectations for transparency have increased along with concerns about a lack of comparability or consistency in disclosures. This Practical tip focuses on the U.S. GAAP disclosure requirements and considerations relating to undistributed foreign earnings.
Ordinarily, a company preparing an SEC filing must apply all accounting standards (including transition provisions) as if it had always been a public company. The JOBS Act of 2012, however, provides an exception to this general rule. Under Section 102(b) of the JOBS Act, an emerging growth company (EGC) may apply any new or revised financial accounting standard on the same date a company that is not an issuer (as defined in the Sarbanes-Oxley Act) is required to apply the new or revised accounting standard, if the standard applies to a non-issuer. This Practical tip highlights that an EGC should evaluate whether it needs to make disclosures relating to transition to new or revised accounting standards in its next SEC filing.
Upon adoption of the FASB's new comprehensive income presentation requirements (ASUs 2011-05 and 2011-12), an entity should report a total for comprehensive income in condensed consolidating financial information and parent company-only financial information in a single continuous statement or in two separate, but consecutive, statements. This Practical tip further explains this guidance and includes examples to help you apply it in practice.
In a company's annual financial statements, a three-step incremental approach -- commonly referred to as a "with and without" approach -- is used to allocate the annual period's tax provision (benefit) to continuing operations and other components of comprehensive income and shareholders' equity. This Practical tip summarizes the considerations and provides an example of applying the "with and without" model in interim periods.
When a company obtains control of a foreign investee, it remeasures its previously held equity interest to fair value and recognizes a holding gain in income. This holding gain will generally not result in a current tax event. This Practical tip explains the requirement to freeze any previously recorded deferred tax liability and an accounting policy election that may be available in relation to recording deferred taxes on such holding gains.
Rule 10-01(b)(1) of Regulation S-X requires companies to include separate summarized income statement information in their interim financial statements for each equity investee if (i) separate financial statements of the investee would be required for annual periods and (ii) the investee would be required to file Part I of Form 10-Q if the investee were a registrant.