A Comparative International Analysis of the Impact of Accounting Principles on Profits: The USA versus the UK,Sweden and The Netherlands

This paper explores the extent to which there are material quantitative differences in profits reported under US GAAP compared to profits reported in accordance with generally accepted accounting principles in the UK, Sweden and the Netherlands. From an analysis of Form 20-F reports filed with the SEC in the USA, there is support for the hypothesis that UK GAAP are significantly less conservative than US GAAP. On the basis of a case study approach, it seems that Swedish GAAP tend to be more conservative than US GAAP, particularly when the transfers to reserves are analysed, but there is insufficient evidence to establish a systematic pattern. In the Netherlands, on the other hand, there is evidence to suggest that Dutch GAAP are at the less conservative end of the spectrum of financial reporting measurement practices, in a position relatively similar to that of UK GAAP, although again the evidence is insufficient to establish a systematic pattern.     

Changing from German GAAP to IFRS or US GAAP: A Survey of German Companies

Since 1993 an increasing number of listed German companies have been publishing their consolidated financial statements in accordance with either IFRS or US GAAP. In 1998 this was approved as a substitute for the consolidated German GAAP financial statements of listed companies (§292a HGB). Our study surveys the motives that led these companies to opt for international reporting systems (IFRS or US GAAP) rather than German GAAP and considers whether these objectives have been achieved. Rather surprisingly, we find that even though companies state that their overall expectations have been met to a satisfactory degree, a detailed analysis shows that several of the ex-ante objectives have not been achieved from an ex-post point of view. Additionally, we use logistic regression analysis to show that companies choosing IFRS rather than US GAAP and vice versa differ distinctly in the objectives they pursue with their choice of international GAAP.     

Detecting accounting fraud in companies reporting under US GAAP through data mining

The accounting fraud detection models developed on financial data prepared under US Generally Accepted Accounting Principles (GAAP) in the current literature achieve significantly weaker performance than models based on financial data prepared under different accounting standards. This study contributes to the US GAAP accounting fraud data mining literature through the attainment of higher model performance than that reported in the prior literature. Financial data from the 10-K forms of 320 fraudulent financial statements (80 fraudulent companies) and 1,200 nonfraudulent financial statements (240 nonfraudulent companies) were collected from the US Security and Exchange Commission. The eight most commonly used data mining techniques were applied to develop prediction models. The results were cross-validated on a testing dataset and then compared according to parameters of accuracy, F-measure, and type I and II errors with existing studies from the US, China, Greece, and Taiwan. As a result, the developed predictive models for accounting fraud achieved performance comparable to those achieved by models built on data from other accounting standards. Moreover, the developed models also significantly outperformed (accuracy 10.5%, F-measure 16.1%, type I error 12.2% and type II error 15.2%) existing studies based on US GAAP financial data. Furthermore, this study provides an extensive literature review encompassing recent accounting fraud theory. It enhances the existing US fraud data mining literature with a performance comparison of studies based on other accounting standards.     

The Impact of Financial Accounting Practices on the Measurement of Profit and Equity: Australia Versus the United States

The purpose of this paper is to make a quantitative comparative analysis of differences between Australian financial reporting practices and U.S. GAAP. The empirical data consist of Form 20-F filings for thirteen Australian incorporated companies for the period 1985–93. Based on prior research, there is a test of the hypothesis that U.S. GAAP is more conservative than Australian financial reporting practice. The results of the empirical analysis offer little support for this hypothesis in the context of the reporting of profit. However, the hypothesis is supported for the reporting of shareholders’ equity. The most frequent and material differences in profits relate to asset measurement, equity consolidation and accounting for intangible assets. Generalizations relating to differences in shareholders’ equity are more difficult to make.     

Measuring the impact of international reporting standards on market performance of publicly traded companies

The decision whether to require publicly traded companies to adopt International Financial Reporting Standards (IFRS) remains in flux. In 2008, the US Securities and Exchange Commission proposed a roadmap leading to complete acceptance of IFRS in the US. With the potential replacement of US GAAP with IFRS in the near future, understanding the impact of IFRS on corporate financial reporting is more important than ever. This study examines two factors which are critical considerations in the decision to accept or not to accept IFRS in the US: How different is financial statement information derived under IFRS from information derived under US generally accepted accounting principles (GAAP); and how much incremental information value, if any, is provided by IFRS over US GAAP? The present study extends prior research by examining concurrently both differences and their impact on market performance. Findings of this study support the view that differences on financial statement results between IFRS and US GAAP are not significant, thus, supporting proponents of adoption of IFRS in the US, after which all US publicly traded companies would use IFRS and not US GAAP.     

Does accounting choice influence US investment in non‐US companies? Evidence from US institutional investment in Australian companies

Previous research asserts that companies that choose accounting methods more familiar to investors reduce information asymmetry and increase credibility of their financial statements to those investors, thereby attracting higher levels of foreign investment. This study examines the variation in accounting policies associated with institutional investment in Australian equity. The results suggest that large US institutional holdings in Australian companies are associated with American Depositary Receipt listing and, incrementally, choice of accounting methods that conform to US Generally Accepted Accounting Principles (GAAP). Although making accounting choices in compliance with US GAAP is significantly associated with higher levels of institutional ownership in a statistical sense, examination of the specific differences in accounting choices suggests that the differences in informational content are relatively minor.     

Transitioning to IFRS in Japan: Corporate Perceptions of Costs and Benefits

This paper examines the ongoing transition to International Financial Reporting Standards (IFRS) in Japan with a particular focus on recent institutional developments and corporate concerns. While Japan has committed to the convergence of Japanese generally accepted accounting principles (J‐GAAP) with IFRS it has not as yet formally adopted IFRS. This paper reports on Japanese corporate perceptions of the likely costs and benefits of adopting and implementing IFRS using survey data collected from senior financial executives of 292 Japanese listed companies in 2013–14. Our findings reveal that Japanese companies identify a number of major areas of general concern with the adoption and implementation of IFRS. Most importantly, uncertainty regarding the interpretation of standards followed by staff training, IT systems, technical knowledge and differences between J‐GAAP and IFRS were reported as major concerns. Our survey also highlights that revenue recognition, depreciation, consolidated financial statements, financial statement presentation and the retrospective application of IFRS were viewed as key IFRS accounting issues. While the large majority of companies expected a moderate degree of benefits to arise from IFRS, substantial benefits were perceived more likely to apply to large and overseas listed companies mainly arising from improvements in the international comparability of financial statements.     

German Reporting Practices: An Analysis of Reconciliations from German Commercial Code to IFRS or US GAAP

This paper presents the results of research analyzing reconciliations of net income and stockholders’ equity from reports prepared according to Germany's Commercial Code (HGB) to either International Financial Reporting Standards (IFRS) or US Generally Accepted Accounting Principles (US GAAP). We describe the distribution of the reconciling items and assess their value relevance to firm market values 3 months after the financial statement date. The work helps to identify many issues not apparent from research that focuses only on promulgated accounting standards. Among other things, the research presented in this paper demonstrates that, when reconciling to IFRS or US GAAP, German companies must reverse significant software and film licensing revenue. Other areas of significant difference, not surprisingly, show greater conservatism in reporting under HGB than IFRS or US GAAP, particularly in asset capitalizations and write-offs as well as in accruals of provisions and reserves. The latter category is value relevant to the firms’ market values after controlling for all other categories of reconciling items from HGB to either IFRS or US GAAP, indicating that German markets value these companies’ provisions and accruals under the German reporting system.     

Implications of the mandatory transition from national GAAP to IFRS — Empirical evidence from Germany

This paper analyses the differences between German GAAP and IFRS by quantifying the effects of the first-time adoption of IFRS of German companies in their reporting practices. Due to the IAS Regulation EC No.1606/2002, all publicly traded European companies (including those in Germany) are required to prepare their consolidated financial statements in accordance with IFRS for accounting periods beginning on or after January 1, 2005. This paper measures the effect of the transition from German GAAP to IFRS by using indices of comparability that were developed by Gray (1980). Therefore, the impact on equity and net income is quantified by examining the reconciliations of 103 German companies which had to adopt IFRS for their consolidated financial statements in 2005. On average a significant increase in stockholders' equity and in net income could be observed. The increase in stockholders' equity is primarily due to the adoption of IAS 11, IAS 16, IAS 37, IAS 38 and IFRS 3. Concerning net income, the increase especially results from the adoption of IFRS 3.     

Convergence between US GAAP and IFRS: Acceptance of IFRS by the US Securities and Exchange Commission (SEC)

Abstract

The world's capital markets stand to benefit significantly from widespread acceptance and use of global accounting standards that are high quality, comprehensive and rigorously applied. The US Securities and Exchange Commission (SEC) announced in April 2007 a series of actions it intends to take relating to the acceptance of International Financial Reporting Standards (IFRS). To implement this, the SEC proposed in July 2007 amendments to Form 20-F and conforming changes to SEC Regulation S-X to accept financial statements prepared in accordance with IFRS without reconciliation to US Generally Accepted Accounting Principles (GAAP) when contained in the filings of foreign private issuers with the SEC. This paper analyses the forces driving convergence between US GAAP and IFRS and discusses the most recent activities by the SEC in relation to IFRS and international cooperation, including the SEC vote as of 15 November 2007, to allow foreign private issuers to prepare their financial statements using IFRS as issued by the IASB without reconciling to US GAAP.     

IFRS in the United States – Developments and Current Status

International Financial Reporting Standards (IFRS) are now required or permitted for use by companies in more than 100 countries, including the majority of the G20 members. However, domestic public companies domiciled in the United States (US) continue to be required to file financial statements with the Securities and Exchange Commission (SEC) in accordance with US Generally Accepted Accounting Principles (US GAAP), and are prohibited from preparing them based on IFRS. This article describes the developments of IFRS‐related activities and initiatives in the US over the period 2007–2012, and provides an overview of the current status regarding potentially incorporating IFRS into the US financial reporting system based on recently issued reports by the SEC.     

The subprime crisis and its consequences

Having started by describing the background to the crisis, the paper considers priorities for action by the financial industry, being: (1) improved transparency; (2) review valuation issues, notably the distinctions between IFRS and US GAAP on asset reclassification; (3) better risk management, with an appropriate mix of quantitative and qualitative metrics; (4) Improved market infrastructure, perhaps including a central counterparty for OTC derivatives; (5) an external review of ratings agencies’ processes; (6) enhanced liquidity risk management. An assessment of the measures taken by central banks to allay the crisis follows, and we conclude with an analysis of the strategic consequences for the financial industry.     

Gemini Communications: A case applying revenue recognition standards

Gemini Communications (Gemini) is a case study on revenue recognition criteria. You will take on the role of an audit manager for the public accounting firm that audits Gemini. Your client, Gemini, is a US company that recently expanded operations into China through the acquisition of Apollo Man. Gemini prepares its financial statements in accordance with US Generally Accepted Accounting Principles (US GAAP) while Apollo Man prepares its financial statements in accordance with International Financial Reporting Standards (IFRS GAAP). Your assignment is to research, compare and contrast the technical criteria for revenue recognition under US GAAP, IFRS GAAP, and the proposed revenue standard. You will apply the various criteria to an Apollo Man sales transaction to determine the timing and amount of revenue Apollo Man should recognize. The case is designed to develop your research and written communication skills.     

Have ‘European’ and US GAAP measures of income and equity converged under IFRS? Evidence from European companies listed in the US

The EU's adoption of IFRS, combined with the SEC's removal of the US GAAP reconciliation requirement for non‐US registrants reporting under IFRS, signifies a major shift towards the acceptance of global standards. Based on 20‐F reconciliations provided by the population of US listed European companies filing IFRS‐based statements with the SEC in 2005, we examine whether ‘European’ and US GAAP measures of income and equity converged under IFRS. We find that during the period immediately preceding IFRS, for our sample companies, European and US GAAP measures are generally comparable in respect of income and equity. However, as an exception to the latter, we find that UK GAAP yielded significantly lower measures of equity than US GAAP For companies adopting IFRS for the first time in 2005, we find a significant gap between IFRS and US GAAP measures of income, thereby, signifying de facto divergence from US GAAP in regard to income determination. Furthermore, we find that, following IFRS adoption, significant differences with US GAAP equity persisted for companies that previously reported using UK GAAP. Our findings, thus, support critics’ claims that standard‐setters, most notably the IASB and FASB, have more work to do to achieve a sufficient degree of convergence between IFRS and US GAAP that will convince the SEC to require US companies to use IFRS.     

Using Form 20-F reconciliations to internationalize an accounting course

Accounting courses and textbooks in the United States focus on US generally accepted accounting principles (GAAP). As a result, US accounting students have little exposure to International Financial Reporting Standards (IFRS) and to differences between these standards and US GAAP. To familiarize students with the differences between IFRS and US GAAP, accounting instructors can develop assignments based upon the reconciliation of IFRS to US GAAP net income included in Form 20-F, the annual document submitted to the SEC by non-US firms. The course assignment described in this paper provides students with a “road map” of the differences underlying specific company financial reporting, and helps instructors identify where these differences occur. The assignment represents an innovative way of integrating international financial reporting standards and SEC reporting requirements into a higher level undergraduate or graduate accounting course.     

Financial Reporting for Private Companies: The Canadian Experience*

The issue of whether small and/or private companies should be allowed to use simplified accounting standards in financial reports has concerned the accounting profession for decades. It has been argued that preparing financial reports in accordance with the large volume of promulgated standards contained in generally accepted accounting principles (GAAP), some of which are relatively complex, has put a significant strain on the resources of small/private business. Moreover, information produced and presented in accordance with at least some accounting standards within GAAP may not be relevant for the users of small/private companies' financial statements. In this paper we look at differential reporting in Canadian GAAP, which gives nonpublicly accountable enterprises the ability to opt out of certain CICA Handbook requirements with unanimous consent of the shareholders. We look at lobbying activity in response to the proposed differential reporting standard and at nonpublicly accountable company experience with the differential reporting opportunity in the period since the standard was promulgated.     

An Investigation into the Potential Adoption of International Financial Reporting Standards in the United States: Implications and Implementation

International Financial Reporting Standards (IFRS) have been adopted by most of the G20 countries. Given the broad worldwide acceptance of IFRS and significance of attaining comparability to facilitate free flow of capital, the US standard setter, the Financial Accounting Standards Board (FASB) made a commitment to jointly work with the International Accounting Standards Board (IASB) to explore the possibilities of convergence of US Generally Accepted Accounting Principles (GAAP) with IFRS. In 2007, the US Securities and Exchange Commission (SEC) eliminated the requirement that foreign companies listed on the US stock exchanges reconcile their IFRS‐based financial statements with the US GAAP. In the same year the US SEC issued a concept release to the public requesting comments on a proposal to allow US issuers to prepare financial statements in accordance with IFRS. Following these initiatives by the FASB and SEC, the aim of the present study is to investigate the implications of a potential full adoption of IFRS by the US. The present study details the challenges and benefits of adoption and outlines the steps required for a successful outcome of this process.     

美国企业储蓄率变迁的内外因素分析——基于1991-2016年的数据

美国企业储蓄率在1991-2016年间稳中有升,其直接原因是与美国企业未分配利润的持续增加有关,深层次原因则是近年来美国企业利润的不断上升;进一步分析发现,美国企业利润的上升与其海外利润和金融业利润的增加密不可分,而这一切既受到美国国内因素的影响,又受到国际因素的影响。从国内因素来看,管制的放松、大型跨国集团尤其是金融集团的构建,以及对冲基金的国际金融投机,为美国企业海外利润和金融业利润的扩张奠定了丰厚的基础。从国际因素来看,美国在思想领域掌握经济话语权,引领和鼓动别国主动开放金融市场,以及对于符合美国经济思想的海外代理人的培养,使开放资本市场变成发展中国家的一种自觉行动。此外,通过操控国际经济机构逼迫别国开放市场,为美国企业的海外拓展大开方便之门。     

A case against the consolidation of foreign subsidiaries’ and a United States parent’s financial statements

Generally accepted accounting principles in the United States usually require that companies which own more than 50% of the voting stock of foreign corporations prepare consolidated financial statements. The foreign financial statements must be recast into US GAAP and the foreign currency financial statements must be translated into US dollars. Alternative methods of translating foreign currency have major impacts on consolidated financial statements and on the behavior of management. Further, foreign subsidiary financial statements which are recast into US GAAP are less useful than the originals, and US users cannot analyze them without reference to the foreign environment. The interests of financial statement users are better served by alternative presentations of foreign currency denominated accounts rather than by consolidation.     

China's Convergence with IFRS: Analysis of Dual-listed Companies

This study investigates China's convergence towards International Financial Reporting Standards (IFRS) using generally accepted accounting principles (GAAP) differences data disclosed in AH-share companies’ annual reports from 2006 to 2017. We firstly find that 92% of AH-share companies disclosed GAAP differences in 2006, immediately prior to implementation of converged Chinese accounting standards (CAS). This ratio decreased to 88% in 2007, 58% in 2010, and 38% in 2011, respectively. After 2011, less than one third of AH companies disclosed GAAP differences. Secondly, an increasing number of AH companies (35%) have published CAS-based financial statements in Hong Kong from 2014. Thirdly, except for the first few years after 2007, the disclosed GAAP differences have dropped to a very low level; since 2010 the net profit and net assets GAAP differences ratios have been below 0.5%. Fourthly, reduction of the disclosed GAAP differences appears to be the result of efforts by Chinese standard setters and regulators, work related to the International Accounting Standards Board, or changes in China's special socio-economic environment. Distinct from word-by-word comparison between CAS and IFRS, this research shows that China has achieved its original goal, namely an enterprise applying CAS should produce financial statements that are the same as those of an enterprise that applies IFRS. Our findings provide insights regarding China's institutional evolution in terms of the country's IFRS convergence effort, which are useful for further empirical study.