Comparison between U.S. GAAP and International ... - Grant Thornton
Comparison between U.S. GAAP and International ... - Grant Thornton
Comparison between U.S. GAAP and International ... - Grant Thornton
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<strong>Comparison</strong> <strong>between</strong> U.S. <strong>GAAP</strong> <strong>and</strong> <strong>International</strong> Financial Reporting St<strong>and</strong>ards 93<br />
IFRS<br />
instruments<br />
IAS 39 has highly detailed requirements concerning<br />
derivatives, complex instruments (such as embedded<br />
derivatives) <strong>and</strong> hedging arrangements. Derivatives<br />
such as interest swaps, forward contracts, <strong>and</strong> currency<br />
options are carried at fair value.<br />
U.S. <strong>GAAP</strong><br />
Similar to IFRS. Derivatives <strong>and</strong> hedging arrangements<br />
are covered by ASC 815 (see Section 7.3, “Recognition<br />
<strong>and</strong> measurement of derivatives” <strong>and</strong> Section 7.4, “Hedge<br />
accounting”).<br />
Categorisation of financial assets<br />
Divide financial assets into the following categories<br />
(IAS 39.9):<br />
• Financial assets at fair value through profit or loss<br />
(see below for further details)<br />
• Loans <strong>and</strong> receivables (see below for further<br />
details)<br />
• Held to maturity – defined narrowly with strict<br />
conditions; covers only assets with fixed or<br />
determinable payments <strong>and</strong> fixed maturity that the<br />
enterprise has the positive intent <strong>and</strong> ability to hold<br />
to maturity, other than loans <strong>and</strong> receivables<br />
originated by the enterprise<br />
• Available-for-sale financial assets – all financial<br />
assets not falling under another category (any<br />
financial asset other than one that is held for trading<br />
may be designated into this category on initial<br />
recognition)<br />
No explicit categorization scheme for financial assets.<br />
They could be categorized as follows:<br />
• Derivative financial instruments (see Section 7.3,<br />
“Recognition <strong>and</strong> measurement of derivatives”)<br />
• Hybrid financial instruments that would be required to<br />
be separated into a host <strong>and</strong> derivative component<br />
under ASC 815-15-25-1 which the entity has<br />
irrevocably elected to measure at fair value<br />
(ASC 815-15-25-4)<br />
• Eligible financial assets that the entity elects to<br />
measure at fair value – fair value option<br />
(ASC 825-10-15-4)<br />
• Loans <strong>and</strong> receivables (see below for further details)<br />
• Debt <strong>and</strong> equity securities within the scope of<br />
ASC 320:<br />
<br />
<br />
Trading (see below for further details)<br />
Held-to-maturity – defined narrowly with strict<br />
conditions <strong>and</strong> covers only those debt securities<br />
that the enterprise has the positive intent <strong>and</strong><br />
ability to hold to maturity<br />
<br />
Available-for-sale – debt <strong>and</strong> equity securities<br />
not classified as trading or held-to-maturity<br />
securities<br />
An entity may not use the held to maturity category for<br />
two annual reporting periods (taint period) when it sells<br />
more than an insignificant amount of assets, with limited<br />
exceptions (IAS 39.9).<br />
Financial assets at fair value through profit or loss<br />
include (IAS 39.9):<br />
• Assets held for trading – includes all derivatives<br />
(see Section 7.2, “Presentation, recognition, <strong>and</strong><br />
measurement of financial liabilities <strong>and</strong> equity” <strong>and</strong><br />
Section 7.3, “Recognition <strong>and</strong> measurement of<br />
derivatives”) as well as other instruments acquired<br />
for the purpose of generating profit from short-term<br />
fluctuations in price or dealer's margin<br />
• Financial assets designated irrevocably into this<br />
category on initial recognition if they fall into one of<br />
The length of the taint period under U.S. <strong>GAAP</strong> is not<br />
defined. The SEC uses a two year time frame.<br />
Financial assets at fair value through earnings include:<br />
• Derivative financial instruments (see Section 7.2,<br />
“Presentation, recognition, <strong>and</strong> measurement of<br />
financial liabilities <strong>and</strong> equity” <strong>and</strong> Section 7.3,<br />
“Recognition <strong>and</strong> measurement of derivatives”)<br />
• Trading securities – securities that are bought <strong>and</strong><br />
held principally for the purpose of selling them in the<br />
near term but may include securities held for a longer<br />
period (ASC 320-10-25-1)<br />
• Hybrid financial instruments that would be required to<br />
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