The Financial Accounting Standards Board is churning out guidance on how companies should account for the effects of the Tax Cuts and Jobs Act, with a proposed change to accounting standards and a series of questions and answers.
The FASB issued a proposed Accounting Standards Update to address the stranded income tax effects that companies have been stocking away in “other comprehensive income” in the equity statement. To answer concerns about confusion and mismatching raised by the financial services sector, the FASB is proposing a method of reclassifying certain items from OCI to retained earnings as companies report the effects of the tax legislation.
The proposed change would be accompanied by some transition disclosures, including the nature and reason for the company’s change in accounting principles that would be permitted, a description of information from prior periods that is being adjusted, and the effect of the change on the relevant line items in financial statements.
FASB says the reclassification would occur in each period or periods companies reflect the tax effects of the Tax Cuts and Jobs Act in financial statements. GAAP requires companies to reflect tax legislation changes in the period the law is enacted, but the Securities and Exchange Commission issued Staff Accounting Bulletin No. 118 to permit companies to take up to a year to work out the reporting because of the magnitude of the change and the short window of time permitted for year-end reporting.
In addition to the proposed update to accounting standards, FASB staff members also penned a series of questions and answers meant to clear up uncertainty companies and accounting firms have raised with respect to the tax reform reporting requirements. The staff answered a question around whether companies should discount the tax liability they must recognize on their deemed repatriation of foreign earnings held overseas, which are subject to a new transition tax under the new tax law.
GAAP generally prohibits the discounting of tax liabilities, but the new tax legislation provides for a multi-year transition, which accounting theory would generally say warrants discounted. The FASB staff answer, by the way, is no, the liability should not be discounted.
Guidance also answers questions about whether companies should discount the alternative minimum tax credits that become refundable under the new tax law over a three-year period. No, FASB staff says, that one should not be discounted either. The staff Q&As also dig into how to account for the base erosion anti-abuse tax and how to account for global intangible low-taxed income.
Earlier, FASB staff also addressed whether private companies and not-for-profit entities can follow the measurement period approach to recognizing the tax effects of the new law that the SEC developed and explained in SAB 118.