While working towards convergence, U.S. Generally Accepted Accounting Principles (U.S. GAAP) and International Financial Reporting Standards (IFRS) still diverge enough to materially affect the financial statements. Companies who have entities that report locally in U.S. GAAP and IFRS should be aware of these differences and the impact to their consolidated financials.
Both ASC 606 and IFRS 15, “Revenue from Contracts with Customers,” operate off of the core principle that an entity is to recognize revenue that represents the transfer of a promised good or service to another party at an amount that the entity deems appropriate for the exchange. Both standards also apply this principle with a five steps process:
Create and identify a contract with the customer.
Identify the performance obligations required by the contract.
Set a price for the transaction.
Allocate this set price to each performance obligation.
Recognize the revenue at the satisfaction of each performance obligation.
Although the adoption of these steps has converged many aspects of GAAP and IFRS, there are some differences that separate the two revenue recognition standards. One practical expedient permitted under ASC 606 allows for an election to recognize all revenue at the transfer of control to the customer. Thus, any shipping and handling activities that occur after the customer obtained control of the entity’s good or service can be treated as a fulfillment cost; separate from the original performance obligation. If the practical expedient is not elected, these fulfillment activities are treated as a part of the entity’s performance obligation, and revenue recognition is deferred until the obligation has been satisfied. Since IFRS 15 does not permit for this practical expedient, IFRS entities could be recognizing revenue at a slower rate than U.S. entities.
Another policy election under U.S. GAAP is the presentation of sales tax and other similar taxes. ASC 606 allows companies to elect to exclude sales tax and certain other taxes from the measurement of the transaction price in step three above. If a company reporting under U.S. GAAP decides to make this election, the company then must consider the fact that IFRS does not permit for the same election. Therefore, transactions reported from entities subject to IFRS could carry a different value.
One important point to note is that IFRS 15 permits a practical option for companies to elect either the full or modified retrospective approach for converting to the new revenue recognition standard. The full approach restates financials as if IFRS 15 has always been applied; whereas the modified approach reports a cumulative adjustment at the time of conversion. Under ASC 606, entities must adopt using the full retrospective method by applying the recognition methods to all contacts that are not considered complete at the first day of the earliest period presented.
In order for a revenue contract to be recognizable, both the FASB and IASB approved a collectability threshold that must be met. This threshold requires that entities must determine if the collectability of revenue is “probable” before recognizing it. However, IFRS and GAAP both provide different definitions for the term “probable” in this context. GAAP defines “probable” as if the future events are likely to occur. IFRS defines “probable” as if the future events are more likely than not to occur. This subtle difference remains because changes in this definition would affect more than one standard for both GAAP and IFRS.
The reversal of impairment losses has also been an area for differences in IFRS and U.S. GAAP. Under IFRS 15, impairment losses taken on contract assets (such as the recoverable costs of obtaining a revenue contract, unbilled receivables, etc.) must be reversed when the impairment conditions no longer exist or have improved. However, IFRS 15 permits an upward reversal of the contract asset’s value that would have been determined, net of any amortization, if no impairment had been previously recognized. Under GAAP, no such reversal for impairment losses is allowed.
There are also some other less common differences between the two revenue recognition standards that are beyond the scope of this article. IFRS 15 was effective January 1, 2018 and ASC 606 has staggered effective dates for U.S. public and nonpublic companies.
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