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Dataline A look at current financial reporting issues - PwC

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Financial Instruments project. However, as part of th<strong>at</strong> project the boards continue to<br />

deb<strong>at</strong>e the proposal to apply a three-bucket model, which may affect lessor receivable<br />

impairment accounting. It is unclear whether the boards will reach a converged solution.<br />

See In brief 2012-37, FASB makes key decisions about the revised impairment model for<br />

<strong>financial</strong> assets for additional details.<br />

Lessors of investment property<br />

.38 The initial ED contained a scope exclusion from the proposed model to allow lessors<br />

of investment properties accounted for <strong>at</strong> fair value to continue to use a model similar to<br />

today's accounting for oper<strong>at</strong>ing leases. In light of significant comput<strong>at</strong>ional <strong>issues</strong> with<br />

respect to lessor accounting for portions of assets (e.g., one floor in a multi-story office<br />

building or one store loc<strong>at</strong>ion in a shopping mall), this scope exclusion was l<strong>at</strong>er<br />

expanded to lessors of all investment properties, irrespective of whether the leased<br />

investment property was accounted for <strong>at</strong> fair value.<br />

<strong>PwC</strong> observ<strong>at</strong>ion:<br />

The boards' more recent decision overturns this previous scope exclusion for all<br />

investment property. Similar results are expected in most cases because most lessors<br />

of investment property will not apply the receivable and residual approach. Because<br />

of applic<strong>at</strong>ion of the "consumption of the underlying asset" principle, they will<br />

account for the leases using an approach similar to existing oper<strong>at</strong>ing lease<br />

accounting. The revised ED is also expected to clarify the interaction between the<br />

leases standard and any requirements in IFRS or U.S. GAAP to measure some<br />

investment property <strong>at</strong> fair value. However, certain longer d<strong>at</strong>ed land leases or other<br />

property leases may qualify for the receivable and residual approach (i.e.,<br />

derecognition, gain/loss). Today, these property leases may only qualify for sales type<br />

lease accounting under U.S. GAAP (e.g., because the leased asset is not carried <strong>at</strong> fair<br />

value due to builder profit or other reasons) if there is an autom<strong>at</strong>ic transfer of title.<br />

This may represent a change for some property lessors <strong>reporting</strong> in the U.S. There is<br />

no similar preclusion under <strong>current</strong> IFRS.<br />

Lease term<br />

.39 The threshold for inclusion of extension options in the lease term in the initial ED<br />

was "more likely than not" (a gre<strong>at</strong>er than 50% likelihood of renewal). A common theme<br />

in the comment letters was th<strong>at</strong> this threshold was too low and would be highly<br />

subjective and potentially vol<strong>at</strong>ile in practice. When coupled with the requirement to<br />

reassess every <strong>reporting</strong> period, it would also be very costly to implement and cre<strong>at</strong>e<br />

unnecessary vol<strong>at</strong>ility.<br />

<strong>PwC</strong> observ<strong>at</strong>ion:<br />

One of the primary reasons for including extension options, and not limiting the<br />

accounting to the non-cancellable lease term, is to avoid the potential for structuring<br />

opportunities. For example, one could theoretically structure a 20 year lease as a<br />

daily lease with 20 years worth of daily renewals. In practice, such an arrangement is<br />

unlikely and potentially costly (as the lessor would want to be compens<strong>at</strong>ed for the<br />

rel<strong>at</strong>ed uncertainty and would need to recover tenant specific improvements in a real<br />

est<strong>at</strong>e lease).<br />

N<strong>at</strong>ional Professional Services Group | CFOdirect Network – www.cfodirect.pwc.com <strong>D<strong>at</strong>aline</strong> 15

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