Subtitles section Play video
Welcome to Deloitte financial reporting updates our webcast series for issues and developments
related to the various accounting frameworks. This presentation is bringing clarity to an
IFRS world, IFRS quarterly technical update. I am Jon Kligman, your host for this webcast.
I am joined by others from our National office. Before I tell you about our agenda, a couple
of housekeeping items. If you would like a copy of the slides for reference, they are
available for download on the same webpage that you access the webcast. You can direct
colleagues to the webcast link by referring them to Deloitte Canada Center for Financial
Reporting, which is accessible at iasplus.com. Simply select Canada English from the dropdown
menu at the top right of the webpage. Now let’s get onto our agenda. First you’ll
hear from Kerry Danyluk, who’ll provide some year-end reminders and discuss feedback
and commentary received from the regulators. After Kerry, Alexia Donoghue will discuss
financial reporting implications, various economic developments that we have been experiencing.
After Alexia, we’ll turn the presentation back over to Kerry, who’ll provide an update
on upcoming IASB projects. I would like to remind our viewers that our comments on this
webcast represent our own personal views and do not constitute official interpretive accounting
guidance from Deloitte. Before taking any action on any of these issues, it’s always
a good idea to check with a qualified advisor. Please note that we are not issuing professional
development certificates for this webcast. Please check with your institute or order
regarding potential continuing professional development credits. I would now like to welcome
our first speaker, Kerry Danyluk. Kerry joined Deloitte as a Partner in 2006 with over 20
years’ experience in public practice, standard setting and industry. Kerry is currently a
Partner in Deloitte’s National Assurance and Advisory Services and specializes in a
variety of areas of IFRS, ASPE and not-for-profit accounting. Over to you Kerry.
Thanks Jon. Well if we move into the first slide here on the year end reminders and regulatory
feedback, I guess the first bit of good news, hopefully it’s good news, is that for this
year end there really are not a whole lot of amendments or at least not large amendments
that are effective, that people need to worry about adopting for this year’s financial
statements. There are really instead kind of a series of fairly narrow scope amendments.
We have a list of them, a summary of them provided in Appendix A to this presentation
for your reference and we also went through in some detail related to these amendments
in the first quarter webcast and the link is provided there on your screen. So, one
of the things that we did want to talk about and again this is a little bit of a repeat
from the third quarter webcast, but we did want to just remind people for year end, some
of the things that the Canadian securities administrators have gone through in their
staff notice that they issued in July. So, this slide just has a series of little summaries
of some of the different areas that the regulators focused on.
So, first of all the operating segments. So,
what the regulators were noting here is that there were some failures to disclose revenue
by geographic area and by major customers. So, as you know IFRS 8 includes both of these.
So, on top of just the regular disclosure of the operating segments and the reportable
segments, there are some requirements to also provide revenue by geography and some disclosures
surrounding major customers if there are some and the regulators noted that in some cases
filers were being deficient in this regard. So, just a little reminder there. In terms
of business combinations, the observation there was it was sometimes unclear whether
intangibles have been separately identified in the purchase price allocation and as you
know you have to separately identify all the identifiable intangibles separate from goodwill,
goodwill does not get amortized, whereas the intangibles would tend to, so that kind of
makes bit of a big difference and I guess just another reminder that there is an allocation
period that’s allowed under IFRS 3 the Business Combinations standard. So, if you have done
a business combination late in the year and you didn’t have a chance to finalize the
purchase price allocation, just a reminder that there is a little bit of a time period
that you are allowed up to one year to finalize and gather all the information that you need
to fair value all the separately identifiable items that were required in the business combination.
The next point relates to fair value measurement in IFRS 13. So, IFRS 13 is a reasonably new
standard and the regulators are still observing some areas of comment regarding the description
of valuation techniques and inputs used especially for the Level 3 fair value measurements and
so, you’ll recall that Level 3 fair value measurements are the ones that have the most
subjectivity to them. They are the ones that would have some significant inputs or data
points that are not market observable. So, the standard really requires you to go a little
bit further in terms of describing those non-market observable inputs and perhaps also providing
some sensitivity analysis around that and so the observation there is that may be people
were not being fully compliant with all of those requirements or at least those were
the questions being raised. And then the last point on the slide is impairment
of assets, which has of course been a bit of a theme for the last couple of years now
and so the points here are there are disclosure requirements when an impairment loss has been
recorded and so just to keep in mind that compliance with all of those situations, the
things that gave rise to the impairment and so on, how the impairment was calculated,
some of the assumptions there and the significant areas of judgement. And also remember that
there is a requirement to, of course you know goodwill will tend to be tested every year
for impairment, but for other assets it’s an indicator based test and so just making
sure to keep in mind the indicators and making sure that testing is done when indicators
are present, which might even be in the quarters as well as year end.
So on the next slide, something we haven’t talked about before is some observations coming
out of the SEC and these are SEC comment letters out of the US for companies, foreign private
issuers who file using IFRS. So, these would include certainly Canadian filers who are
SEC registrants and use IFRS. So, the SEC comment letter, Deloitte’s report on that
came out in October 2015 and I think in a couple of slides we have a link, to where
you can find that report if you are interested in going and looking at it, but just for now
a couple of observations regarding some of the commentary that has been raised by these
regulators about companies using IFRS. So, the first comment relates to the situation
where expenses are presented by function. So, as you could see on the slide, we have
got cost of sales, we have got administrative expenses and so on. So, basically kind of
a typical example of functional presentation. So, IAS 1 does require that when this functional
presentation is used that also some disclosure should be provided in the notes regarding
the cost by their nature and so an example of nature would be depreciation, employee
benefits expense and so on. So, when you follow this type of presentation you are supposed
to be providing information about those costs in the notes to the financial statements and
so, just a reminder because the SEC has observed that, that is not always happening.
On the next slide, the point is the use of the line item operating expenses. So, under
IAS 1, you are not required to have this line called operating expenses in the income statement,
but it is a fairly common presentation and if you do use it, there are some parameters
that you can find in IAS 1 in the basis for conclusions, we have quoted the paragraph
reference there on the slide. So, the point here is that we should not be excluding things
that are of an operating nature from the operating activities part of the statement. So, for
example, if we had restructuring expense, it should be up above the operating activities
line, inventory write-down. So, there are a couple of examples that are actually given
in the standard of things that you would not expect to be excluded from that income from
operations line and so, beyond the examples that are given in the standard, there is some
judgment involved of course. Oftentimes, for example, we do see finance expenses below.
So, it is a matter of judgment about where things appear in the financial statements,
but I guess the point is if things are being excluded from the operating activities line,
in other words presented below that, it is possible that, that presentation will be queried
if the reviewer feels that things of an operating nature have been moved too far down, i.e.
below the operating activities line on the income statement.
The next area of comment was around consolidation disclosures. So, a couple of points here.
So, first of all, the IFRIC, so the interpretations committee of the IASB issued a rejection notice
in July 2015, which is noted on the slide and what this means is that they were posed
a question and decided not to provide further clarification in the form of a project to
develop may be some new standards in this area or clarifications to the standards, but
when they did report on this and the reasons for not taking on this issue, the question
that was raised by the person submitting the issue was basically to what extent can we
summarize our disclosures around joint ventures and associates. So, this is getting at IFRS
12, which again is a reasonably new standard where there are some disclosure requirements
regarding material joint ventures and associate. So, basically the investees that you would
equity account for and so the question was can we add them together, aggregate them if
we have got more than one and really the IFRIC rejection notice makes it clear that the expectation
is that if they are material they should not be aggregated and the information should be
disclosed separately for each one. So, that’s one point to keep in mind.
The other area is towards the bottom of the slide and talking about some examples of judgments
that need to be disclosed related to consolidation. So, for example, if you concluded that you
had control over an investee even though you held less than 50% of the voting rights that
would be an accounting judgment that would trigger some disclosure and similarly if you
concluded no control and you hold over 50% of the voting rights that would also be another
disclosable accounting judgment. So, just keep in mind that you have paid attention
to all the accounting judgment disclosure and make sure that the key judgments are being
disclosed in the financial statements, that’s basically the nature of the comments in this
area that the SEC has observed and then just finally on this slide, the next slide is just
a little wrap up of the summary of some other commentary that they have raised.
So, first of all, the first line is about
presenting additional line items where such presentation is relevant to the user’s understanding.
So, the point here is again from IAS 1 and it is fairly judgmental and not really prescriptive
at all, but what it is saying is that if you need to provide or you should be providing
some additional information in the income statement or elsewhere in the financial statements
in order to help with the understanding, if that’s important information, then those
line items should be added and so that was the observation on this point. The next one
relates to mining and mineral properties and potentially oil and gas as well where the
company is following IFRS 6 and has exploration and evaluation expenses or assets and so,
the commentary here from the regulators is requesting some clarification for accounting
policies regarding the types of expenditures that are included in that E&E category and
then finally just some more points on consolidations and around the judgments and in particular
whether joint arrangements qualified as joint ventures rather than joint operations. So,
if you have those kinds of investments, joint arrangements, you are probably familiar with
the judgments that might get made there and if there are such judgments, they should be
recorded and disclosed in the financial statements. So, Jon, with that I’ll turn it back over
to you. Okay, thanks Kerry. I would now like to introduce
our second speaker, Alexia Donoghue. Alexia is a Senior Manager with the National Assurance
and Advisory Services of Deloitte Canada. In this role, she is responsible for monitoring
quality standards for Deloitte’s public company client filings. Alexia also provides
consultative advice to attest and non-attest clients on general securities filings and
financial reporting matters. Over to you Alexia. Thank you Jon. We are now going to spend some
time looking at some of the trends in the current economy and how this may affect your
financial reporting. So, our first topic is foreign currency and though I am going to
discuss the next couple of slides in the context of the Canadian dollar, the comments are applicable
to a number of other currencies as well. So, over the last year or the last 12 months,
the Canadian dollars declined significantly with an average conversion of 0.797 USD compared
to 0.914 USD for the 12 months ended November 2014. This volatility is expected to yield
significant foreign exchange movements through the statement of income and/or the statement
of other comprehensive income or loss depending on the currencies in which companies operate.
It’s not all bad news with regards to the depreciation of the Canadian dollar. For example,
there may be some entities with US dollar local currency transactions where when they
are converting to Canadian dollars will see an uptick in the carrying value of their net
assets. Given the movement in the Canadian dollar and the volatility, it is expected
that entities will update their IFRS 7 financial instruments disclosures to address new and/or
increased risk associated with foreign currencies and the impact that it has on their financial
results. It is also expected that entities will be revising their MD&A disclosure and
based on the review of some recent MD&A disclosures, in my opinion some of the most effective communication
of the impact of foreign currency changes has been disclosures that have isolated the
foreign exchange component when discussing period over period results.
In addition, we would just like to remind listeners that functional currency is the
currency of the primary economic environment in which an entity operates and it is determined
in the context of the primary and secondary indicators that are set out in IAS 21 and
is done on an entity by entity basis. So, to the extent that you are a company that
may have seen a reduction in their buying power and therefore has made both a strategic
and long-term permanent move to a new economy, you need to assess whether this could potentially
be triggering a reassessment of functional currency for that entity that you moved over.
Next, we are going to look at the presentation
implications of the depreciation in the Canadian dollar. So, IAS 21, the effects of changes
in foreign exchange rates requires an entity to disclose the amount of exchange differences
recognized in profit or loss except for those arising on financial instruments measured
at fair value through profit and loss. IAS 21 is, however, silent with regards to the
appropriate classification of where those foreign exchange gains and losses should go.
The general consensus seems to be that foreign exchange gains and losses should be classified
based on the nature of the transactions or events that actually gave rise to those gains
and losses. For example, it may be appropriate to record foreign currency gains and losses
on operational items, such as trade receivables and payables within income from operations
and foreign exchange gains and losses on issue debt as part of finance costs. Ultimately,
the classification of your foreign exchange gains and losses and profit and loss is a
matter of accounting policy and it must be disclosed as part of your accounting policies
and applied consistently year over year. In addition, when the impact of foreign exchange
gains and losses is material as dictated by IAS 1, the nature and the amount of gains
and losses should be disclosed separately either in the statement of income or loss
and/or other comprehensive income or loss or in the notes. Therefore, when you have
got an entity that previously classified their foreign exchange gains and losses on operating
items, let’s say within selling and administrative expenses and the impact of these gains and
losses becomes material in the year, the entity may elect to present those foreign exchange
gains and losses as a separate line item within income from operations. So, as Kerry discussed
as part of their operating activities, but not necessarily within the selling and administrative
expense line item. The only consideration there is that a change in presentation for
those gains and losses may actually trigger IAS 1 and IAS 8 disclosures in the current
year if the change in presentation also represents a change in accounting policy and with that
let’s think about some impairment implications. When a local currency declines relative to
an entity’s functional currency, there is a higher likelihood that the impairment assessment
will indicate that an impairment charge should be recorded. However, a decline in the local
currency alone does not indicate that an asset is impaired. Analysis should be performed
to determine whether or not an impairment charge should be recorded. So, when we are
determining the recoverable amount for impairment purposes and we are looking at future cash
flows that are going to be applied, the future cash flows should be estimated in a currency
in which they are going to be generated. So, if your revenue is being generated in USD
regardless of what your functional or your presentation currency would be, you would
record all those cash flows in USD and then you would discount using a discount rate that
is appropriate for that currency. Basically, what the guidance is saying is that you translate
the present value of those cash flows using the spot exchange rate at the date of the
calculation because the spot rate reflects the market’s best estimate of future events
that will affect that currency.
So, let’s put this all into context. We have got an example here on the page and let’s
say that we have got a subsidiary A and it’s got an indicator of impairment for the year
ended 2015. The subsidiary A operates in Brazil, but it has a USD functional currency and let’s
also assume that subsidiary A represents a CGU for impairment purposes. So, in determining
the recoverable amount of subsidiary A given the indicator of impairment, we would calculate
all of the future cash flows and then we would forecast them in Real and then we would discount
it back at a rate that reflects the risk associated with the Brazilian Real. Once we have got
this present value in the local Brazilian currency, we are going to convert the present
value into US dollars, which is our functional currency at the spot rate at the date of the
test. The resulting US dollar denominated value in use calculation or recoverable amount
is then compared to the US dollar carrying amount to determine whether or not there is
an impairment, but what happens if on top of this subsidiary there is a parent and that
parent is using a Canadian presentation currency. Do we have another requirement to test for
impairment and in Canadian dollars? The answer is no. The net assets of subsidiary A would
be translated from USD into the Canadian presentation currency at the foreign exchange rate as at
the date of the statement of financial position and then the impairment that is included in
the subsidiary level would also be translated into Canadian dollars using the average rate
and that would be reported in the Canadian financials in the P&L. So, basically any translation
amount that we have incurred by going from the USD functional into the Canadian reporting
amount would just be reflected through OCI or P&L respectively without the need to do
a reassessment. So, we are going to talk a little bit more
about impairments now that sort of leads us into the when, what and how for financial
assets and this is a little bit of a review in terms of what we have previously presented,
but just some key reminders again going back to the CSA report and also just some general
feedback that we have received in terms of regulators comment letters. So, when to test?
When there is an indicator of impairment regardless of an indicator being present at a minimum
for goodwill, intangible assets with an indefinite life and intangible assets that are not available
for use, there is a need for an annual impairment test and then in certain circumstances as
dictated by the IFRS. The most commonly identified would be classification into held for sale.
Management should be performing their test at the lowest level first based on where the
indicator is present. So, I think most frequently you would have an indicator at the CGU level,
so you would test at that CGU level before testing at a larger CGU group level. So, it
would be basically assuming your CGU is, I am going to say like a manufacturing plant
and if there were indicators with regards to the economic environment you would first
test the manufacturing plant and then you would look at the larger group. Let’s say
there were some intangible assets associated with sort of the goods that you are producing
within that process, you would include that as part of the CGU and sort of move up until
you have tested everything and in terms of what you are actually testing or what you
are comparing, you are looking at the carrying values and then comparing that to directly
attributable assets and assets that are allocated on a reasonable and consistent basis less
liabilities used to determine the recoverable amount. So, really it’s the carrying value
versus your recoverable amount and that can be done using either the value in use or the
fair value less cost of sale method.
So, let’s look at some indicators for impairments and so here listed on our slide we have both
got external and internal indicators. We have talked about some significant changes in the
economic environment as it relates to currency on the previous slides, but we can also talk
about it in the context of commodity prices. So, as many of us know the price of oil has
dropped from $100 a barrel to almost $40 a barrel, palladium prices, which is used in
catalytic converters and a number of different other industries has dropped from $786 to
$552 and also is included on the graph on the right hand side. There has been a lot
of volatility in the price of gold over the last year. So, volatile commodity prices have
a direct impact on industries producing those commodities, but they also have a significant
impact on the range of entities that are dependent on those commodities as a key input for their
cost structure. So, basically given the significant fluctuations in the commodity prices, we would
also expect that there would be a number of indicators of impairment and that they would
be prevalent in terms of people therefore assessing whether or not they need to record
an impairment in their financial statements. So, if we go back again to the two graphs
we presented on the slide, just the volatility, if we think about that volatility, where and
how does it impact some of the calculations from a financial reporting perspective. Those
are key inputs that would impact the impairment testing under IAS 38 in terms of determining
the recoverable amount to the extent that we were talking about inputs in determining
the net realizable amount of inventories under IAS 2, but we also need to think about key
inputs related to currency and commodity prices in determining fair value measurements of
assets that are acquired in the business combination and also when thinking about the useful life
of property, plant and equipment and intangible assets. So, indicators of impairment absolutely,
but also have a trickle-down effect in terms of the measurement of some of the key assets
found on one’s balance sheet and then the next sort of indicator we are going to talk
about is when your net carrying amount. Sorry, if we could just go back to the other side,
we are just going to look at some other ones. The net carrying amount when it is in excess
of the market capitalization and this is something we talked about in some previous webcast and
really what it is, is with the existence of this indicator you don’t necessarily have
an impairment. So, there are certainly some questions you need to ask, but it is one of
the specific indicators set out in the guidance. From an internal perspective, it’s usually
more obvious in terms of what may be some indicators of impairment. So, obsolescence
or physical damage to an asset, if you have a fire in a portion of your warehouse, that’s
certainly an indicator of potential impairment and then also I would say a shift in consumer
consumption with regards to the use of an asset. So, that second point often cannot
be predicted and can certainly result in a downturn in terms of results and with that
we’ll move over to the assets held for sale. So, I think this is a topic that I’m going
to say people kind of struggle with. So, we just thought we’ll cover it here leading
into year-end again as we tie it back to some significant fluctuations that have occurred
in our economic environment. So, an available-for-sale equity investment is impaired when two criteria
are met. The first is that its fair value has declined to below cost and the second
is that there is objective evidence of impairment. So, what would be objective evidence of impairment
and really what the guidance says is that it most likely would involve a series of loss
events that points to the fact that the cost will not be recovered. So, examples that they
use would be a significant financial difficulty had by the entity itself or increasing probability
of bankruptcy over a period of time tying it back to some of the indicators we saw on
the previous slide, significant changes with an adverse effect in the local environment
in which the issuer operates may also indicate that the cost may not be recovered and what
we are going to actually, the final sort of indicator, if you will and what we’ll talk
about in a little more detail is whether or not there is a significant or prolonged decline
in the fair value of an investment in an equity instrument below its cost.
So, the first thing that we are just going to think about when we are looking at this
criteria is the fact that the assessment should always be done relative to the original cost
on the date of initial recognition. So, this is actually a point that was considered by
IFRIC a number of years ago, because I think what people were struggling with is what the
point of comparison was as they were doing this assessment of significant and prolonged
decline. The IFRIC also went onto clarify that what constitutes a significant or prolonged
decline in fair value is actually a matter of judgment and that an entity could develop
some internal guidance to assist with the consistent application of this judgment, but
there may be facts and circumstances that would override the policy. So, if we just
want to walkthrough a quick example, let’s say an entity has defined their policy such
that significant is determined to be a 15%-20% decrease in the fair value and prolonged is
deemed to be a period greater than nine months. If we look at the diagram on the screen, so
the initial cost is that dashed line that runs through the middle and then the solid
line would be the fair value of the equity instruments over the passage of time, you
can see at Q1, probably there is no impairment whereby the fair value equals initial cost,
at Q2 we have had an increase in the fair value and then at Q3 we can see that there
has been a decline in the fair value of our equity instrument.
So, our first assessment would be to look back at our internal policy and compare the
price as at the reporting date to our initial cost and determine whether or not of significant.
You know in determining their internal policy, the entity may have considered that a volatility
of 5%-10% is normal for the industry in which this equity exists, but, if it is in excess
of that volatility it’s definitely an indicator of impairment, then an impairment would be
recorded and then the other thing is to look at time. So, if we look at sort of it’s
been nine months since the initial recognition of our equity investment, but it’s only,
so determining whether or not that also is a reason to record an impairment.
Okay, so next thing we are going to talk about is discount rates. So, the Bank of Canada
has not done much in terms of our interest rate or risk free interest rate and so our
question to you is which of the following standards requires the use of a discount rate
and if you have answered all of those shown on the slide then you are correct. So, this
is just really a friendly reminder to let you know that there are a number of standards
that require the calculation in the application of discount rates at each reporting period
and that just that these amounts need to be revisited. I’ll just touch on some of them
quickly. So, as I mentioned the Bank of Canada, the risk free interest rate is sitting at
about three quarters of a percent right now, which is down from 1% as of July or I guess
June of this year, that is often the starting point for IAS 37 provisions to the extent
that entities actually put the risk associated with future cash flows into the cash flows
themselves. So, it’s just really that we need to be consciously assessing whether or
not the appropriate risk has been embedded into the inputs and the cash flows and also
that when we are looking at the different discount rates that we are ensuring compliance
with respective IFRSs and then just moving onto and I guess Kerry touched on this briefly
before, we are going to talk about some fair value considerations.
So, basically fair value is the price that
would be received to sell an asset or paid to transfer a liability in an orderly transaction
in the principal or in the case of IFRS 13 the most advantageous market at the measurement
date under current market conditions. So, really quite a mouthful, but really I think
what reporters need to think about or people who are preparing their financial statements
is whether or not they have really assessed the completeness of their fair value disclosures
and also the completeness of their calculations. So, looking at a number of financial statements,
there seem to be some deficiencies, one in terms of whether or not all items that have
affected both recurring and non-recurring are reflected in the financial statements.
It’s not often clear whether or not there have been adjustments to valuation models.
So, just an example there would be if you had debt that was previously issued and you
were using one valuation model and then you issued some more debt, but that had different
constraints associated with it just whether or not you have modified the valuation methodology
in order to reflect the individuality of that second debt tranche that was issued. Also
a reminder that the fair value hierarchy applies to both financial and nonfinancial assets
and liabilities and often the disclosure included in the financial statements focuses just on
financial instruments. So, we just need to ensure completeness and then also just ensuring
as I was referring to in the discount rate portion is that any non-performance risk or
other risks associated with the fair value of assets and liabilities that is actually
flowing through the methodology. So, the next slide we are just going to look
at some of the required disclosures in the context of fair value measurements and really
this is all in the context or set out in IFRS 13, which basically is asking for entities
to disclose information that will help users understand both assets and liabilities that
are measured at fair value on a recurring and non-recurring basis after initial recognition.
So, just sort of take a step back, if we could just think about or revisit what is meant
by recurring and non-recurring. Examples of recurring fair value measurements would include
investment properties that use the fair value model under IFRS 40 or financial assets at
fair value through profit and loss under IAS 39 and IFRS 9. Really what it is, is assets
and liabilities that need to be fair valued at each reporting period as set out under
IFRS and then by comparison non-recurring fair value measurements include assets held
for sale, which are measured at the lower of fair value less cost to sell and their
carrying amount and again comparatively non-recurring fair value measurements are those that are
required or permitted by IFRS, but only in particular circumstances.
So this slide just shows what the required disclosures are for Level 2 and Level 3 items
and if we are going to tie this back to sort of the feedback that we have been receiving
via comment letters and from regulators, the first one would be with regards to the description
of the valuation techniques, often these descriptions are fairly boilerplate and to be honest they
really just reproduce the definitions of both Level 2 and Level 3 as set out in IFRS 13.
So, really just you know entities should be revisiting their disclosures and ensuring
that they have made them as asset or liability specific as possible in order for readers
to understand what is going into these different underlying measurements. Given and as Kerry
mentioned sort of the number of variables and potential risk associated with Level 3
measurements, I just want to draw your attention that there are a number of additional disclosures
that are required including a reconciliation from the opening to the closing balances in
order to, for users to understand those changes and also with regards to quantitative information
about the significant inputs that are going into the fair value measurements. So, really
just a reminder that we need to ensure that the disclosures one are complete and two that
they are in sufficient detail and specificity that readers can understand what they are
trying to say and just before I turn it back to Jon, I wanted to talk about one more economic
consideration and that’s the Canadian political environment. As some of you might know, included
in the proposed 2015 Federal budget was the rule to make inter-corporate dividends declared
after April 1, 2015 taxable. This is just a reminder that the proposed rule was expected
to be reintroduced when the Trudeau government brings up the next budget. So, although not
an issue for the current year-end, you may want to consider speaking to your tax advisor
in order to start planning for potential implications and potential tax strategies in the event
that this rule is in fact passed and could potentially have an impact on your financial
results and with that I would like to turn it back over to Jon.
Thanks very much Alexia. Lots of challenging issues especially around impairment and fair
value measurement. I would now like to turn the presentation back over to Kerry.
Thanks Jon. So, I guess another piece of good news about
not having too many amendments for year-end to talk about is that it does leave us a little
bit of time to look ahead to what might be coming along in the near future and I am going
to just touch on, this is basically an abridged version of the current IASB work plan. You
can see this work plan at any given time by following the link that’s on the bottom
of the screen. They do update it from time to time and this one is as of October 30,
the last version. So, as many of you will know, we are expecting the Leases project
to result in a final standard within the next three months and I guess the much awaited
implementation date has pretty much been decided to be January 1st, effective for period starting
on or after January 1, 2019. So, I guess the good news is we don’t have to adopt the
Leases standard in the same year that we have to adopt revenue and the new financial instrument
standards in IFRS 9, but soon after that in 2019, I have to be looking towards Leases.
So, I will say a little bit about some of the stuff that they have released some information
about the Leases project. So, I’ll talk about that shortly, but in
the meantime, maybe I’ll just mention a couple of other things that they are working
on. So, you will see a number of entries on this work plan related to the Disclosure Initiative.
So, the first one being we are expecting some final amendments. So, this is going to be
a final IFRS to IAS 7, which is the cash flow statement standard and what those amendments
are focusing on is getting entities to provide information about liquidity and one of the
things proposed in there, which we expect to see in the final standard is actually some
disclosure around reconciling, opening to closing balance related to liabilities and
in particular debt type financing obligations and basically showing in the financial statement
notes, the movements of those in the period. So, that’s something that you might want
to watch for. It will be out probably early next year. So, we don’t really know what
the implementation day will be. Certainly, probably safe to say it won’t be a 2016
implementation day, but may be some point soon after that.
So, a couple of other things to mention IFRS 8, we are expecting in next few months, an
exposure draft, some clarifications around segment disclosures and these come from the
so called post-implementation review that the IASB does. So, when they do a new standard
and IFRS 8 is a relatively new standard, a couple of years after the effective date,
they will do what they call post-implementation review and they are looking for implementation
issues and areas where clarification is needed. So, they have found that there are some areas
related to IFRS 8 that they would like to propose some clarifications and so we can
watch for an exposure draft on that coming shortly. The next one, I guess another definition
of a business in the middle column, that’s another one out of the post-implementation
review this time of IFRS 3, the business combination standard. So, this is an important issue and
it’s one that we often think about in acquisitions of assets especially in the natural resources
and sometimes in the real estate sectors whether the collection of assets that you are buying
meets the definition of a business, in which case it’s covered by IFRS 3 in the business
combination standard or is it just merely an acquisition of assets and then the question
is how do we account for them and there are some differences. You know you wouldn’t
have goodwill in an asset acquisition, transaction costs would get expensed in a business combination,
they get added to the cost of assets in an acquisition that’s not a business acquisition.
So, there are some differences in accounting, which does make the distinction important.
Again we have got Disclosure Initiative again mentioned here and the discussion paper and
as well over on the right-hand side, there are some more entries there for an exposure
draft around changes in accounting policies and estimates out of the Disclosure Initiative
and so there that one is getting at the distinction between a change in policy versus a change
in estimate and then finally at the bottom, there is a Materiality Practice Statement,
that they have issued a paper on that and they are considering comments. So, I guess
the one thing also to mention about the Disclosure Initiative project which is not on this work
plan and that’s because part of it is already finished, they have made some amendments to
IAS 1 around some concepts associated with materiality, the extent to which financial
statement line item should be aggregated and whether individual line items need to be presented
only based on materiality or do they need to be presented simply because they appear
in a list of minimum line items in IAS 1 and so the good news there is they have gone more
towards saying only present things if they are material and so that’s good. I think
the whole objective behind the Disclosure Initiative project is to perhaps get some
streamlining of disclosure happening and just to make sure that really the most important
things are being disclosed in a clear way and in a way so that the information is not
obscured by having a lot of details present in the notes.
So, I think that’s probably good news story anyway. So, that piece of the Disclosure Initiative
that’s finished, those amendments to IAS 1, they are effective for January 1, 2016.
So, will they cause a lot of changes for next year’s financial statements, maybe not,
but they will give some extra food for thought for people in thinking about how and whether
to streamline their disclosures and certainly a lot of encouragement there to try and make
the disclosures more clear and concise. I guess may be one last thing to mention the
Conceptual Framework, which is in the middle column there. They have been working on the
Conceptual Framework update, so that is basically the part of IFRS that sets out things like
definitions of an asset and liabilities, the elements of financial statements and so on.
So, that project they had a discussion paper. They are considering the comments on the discussion
paper. So, we will see probably some activity, more proposals perhaps being presented next
year. So, the comment period on the current exposure draft that’s out related to that
project is actually ending this week, November 25th.
So, I mentioned I was going to talk a little bit about some work that they have or some
of the stuff that they have released related to the Leases project and so that’s on the
next slide and really what they have done here is, you know as I said we are expecting
the final standard, but what the IASB has done and they have actually put it out twice
now, they did a version in February and then they updated it in October. A lot of discussion
and examples surrounding definition of Lease and remember if you have been following this
project you know that the whole objective of the project is to get all those leases,
for lessees to have their leases for the most part on the balance sheet with a right of
use asset and an obligation and so, really distinguishing leases from other kinds of
contracts is becoming even more important than it ever was because you could have a
big difference. If you got a lease, then you will have the right of use asset and an obligation.
Whereas if you don’t, you won’t have those things. So, they have put out this information
statement about some of the guidance that they expect to see in the final standard around
what actually is the definition of a lease.
So, we can see on the slide it has a few elements. So, first of all it depends on the use of
an identified asset. So, this is a uniquely identified asset, there should be no real
substitution rights and then it’s for a physically distinct portion of the asset.
So, either the asset completely in it of itself that’s what is leased or maybe something
that can be distinguished like floors in a building. So, those things would meet the
definition potentially of a lease, whereas something like you know capacity in a fiber
optics cable would not because others will also be using the same cable and you have
just really contracted for some capacity in the cable. So, the other element is that the
contract conveys the right to control the use of the asset for a period of time. So,
the lessee has the ability to direct the use of the asset and make decisions about it and
to receive benefits from its use. So, there could be some critical judgments in here,
whether the customer controls the use of the asset over the period of use.
So, let’s just look at an example on the next slide and really this is just one of
a number of examples that they have included in this little release that they have done,
most recently in October. So, in this case, we have got a contract between a customer
and a freight carrier, the supplier, to provide use of 10 rail cars of a particular type for
five years. The customer determines when, where and which goods to be transported within
certain limitations. If a particular car needs to be serviced or repaired, the supplier is
required to provide a substitute, but that would be the only case during which they would
be able to substitute other cars and then otherwise the supplier as long as the customer
is continuing to pay the lease payments or make the payments, the supplier cannot retrieve
the cars during the five-year period. Now, it’s also a feature of the contract that
the supplier might provide an engine and a driver when requested by the customer as well,
so that we can make the cars move from point A to point B. So, is there an identified asset?
Yes, it’s the 10 cars. They are explicitly indicated or specified and we can’t do substitution
unless there is service needed. The engine and the driver is not an identified asset
because it’s neither explicitly specified nor implicitly specified in the contract.
So, that’s not part of the lease even though it would be a service that would be provided
surrounding the lease. So, if we move onto the next slide, we can
see the considerations here and so the question really is does this represent a lease or does
the contract contain a lease of the rail cars. So, in this particular case because the customer,
they are controlling the right of the use of the asset, the supplier cannot substitute,
it’s the customer who decides when and how to use the cars, the driver is a separate
service essential to the efficient use of the cars, but the supplier’s decisions related
to the engine and the driver do not give it the right to direct how and for what purpose
the rail cars are used. So, in this case, yes contains a lease. Now if we change the
fact pattern and that’s the interesting thing that they do in this little release
they put out as they look at one fact pattern where the thing does constitute a lease and
then they alter up the facts a little bit so that you can kind of see the contrast there
and so if we changed it so that the supplier for example could retrieve the cars, substitute
them, all they really needed to do was kind of provide the capacity of 10 cars, not 10
specific cars, then that one likely would not constitute a lease and it would be a service
contract instead. So, just interesting you could find that release on the IASB’s website
on the project page for the lease project.
So, the next couple of things I am going to talk about are two draft IFRIC interpretations.
So, the IFRIC is of course the interpretations committee that deals with relatively narrow
focus projects of an interpretive nature related to the IFRS standards. So, the first one potentially
an important one, so uncertainty over income tax treatments. So, this is dealing, uncertain
tax positions arise when the tax law or the application of the tax law is sometimes unclear
in certain cases and so companies will have these uncertain tax positions where they have
taken a position it’s not a 100%, that’s the position that would prevail if it was
challenged, but nevertheless that’s the position they have taken and so the question
there is how do we account for that uncertainty and what do we do about that uncertainty from
an accounting perspective. So, of course US GAAP has a standard on this. IFRS never did
and so there was, you know existing practice is for people to either look to IAS 12, which
is the tax standard to try and figure out how to account for these uncertainties or
else look at IAS 37, which is the contingencies and contingent liabilities part of IFRS. So,
the exposure draft is kind of trying to answer the question where should we look and so,
it is referencing, it is indicating that the reference should be made to the tax standard
and so how do we deal with these uncertainties. So, the objective of the standard is for the
entity to consider whether it’s probable, what’s the probable outcome on an uncertain
tax position and so, it talks about using the most likely amount or an expected value
approach and we will look at an example shortly, but, so, really and how do you choose. So,
it is driving you to it. It’s not a free choice. It’s suggested in the exposure draft,
but you should be selecting the method that best reflects the amounts that you would expect
to pay or recover. So, sometimes if there is kind of one really very, the most likely
amount and it’s kind of obvious it will be that amount or maybe nothing or there are
other amounts that maybe have a much lower probability, may be you will be driven to
using the most likely amount versus if there is kind of a range of outcomes then maybe
more of an expected value approach would be the way to go. The draft interpretation tells
you to assume that a taxation authority will examine the filings and has full knowledge
of all the relevant information. So, basically that’s trying to take out sort of the detection
risk out of it. So, you know would they even think to ask that question, would they know
that you are taking that position, would the question even come up on an audit. It sort
of takes that off the table and says like let’s assume that they will examine it and
they will do a thorough job and they will be able to see, the tax authorities would
be able to see and evaluate these uncertain positions and then it also talks about whether,
the proposal talks about whether each uncertain tax position should be considered on its own
or together and really the answer there depends on the facts and circumstances and whether
the positions would stand independently of each other or not.
So, the comments are due on that one in January and again you can find that in the website
if you are interested in looking at it and maybe commenting on the draft interpretation.
So, if we look at the example and this is an example right from the draft. We have entity
B whose tax filing includes a number of deductions related to transfer pricing. It’s not probable
that the tax authority will accept all of the tax treatments and decisions on one will
affect or be affected by decisions on the other, so they are interrelated potentially.
So, entity B concludes that the tax treatments should be considered collectively and the
most likely amount was determined to be 800, but having said that if you look in the example
you’ll see that there is a fairly wide range of possible outcomes and really 800 is only
considered to have a 30% probability. So, while it is the most likely outcome of all
of them, it’s not like it is even hitting the probable threshold in and of itself. So,
the entity then concludes because of the dispersion of these outcomes that they should use an
expected value approach and as a result they record 650 related to this tax position on
that basis.
The other draft interpretation, which is probably a narrow situation, ask the question about
foreign currency transactions involving advance consideration. So, an example would be maybe
you are paying upfront to buy an asset and so, if it’s in a foreign currency, at which
rate should that be translated to the spot rate? So, if we look on the next slide, there
is a little bit of an example. The standard is basically saying to use the earlier of
the date the prepayment is recorded and the date the asset is recorded. So, basically
you are making a prepayment before the asset is received then that would be what you would
pick. So, let’s look at this example. So, we are entering into a non-cancellable contract
with a supplier on March 1st, we paid a non-refundable fixed purchase price on April 1st and then
we take delivery of the machinery on April 15th. So, in this case using the earlier of
proposal set out in the draft interpretation, we translate the prepayment on the date it’s
made April 1st and we don’t change it when we get the machinery. So, the machinery basically
comes onto the books using that same April 1st exchange rate. So, as I mentioned, that
is a January comment deadline as well. So, finally I guess the last thing I am going
to talk about that’s out for comment is the agenda consultation. So, every few years,
the IASB looks at their current agenda and they seek input from stakeholders as to whether
it has the right priorities in the work plan and so on and it really basically goes from
the very basic, early stage research projects to maybe some other projects that are more
advanced. So, we can see on the next slide the basic categories of the projects that
they are considering and the areas of interest that they are looking at. So, there is development
stage, assessment stage and then there is the inactive projects. So, what they are basically
asking for is for people to comment if they would like to on the relative priorities that
should be given to these different projects. So, you can see it’s a fairly lengthy list.
Some of these projects are, potentially might have some pervasive impacts, they are very
topical, others are more narrow. So, I’ll just leave that for your reference. The agenda
consultation paper is available on the IASB’s website and it’s open for comment until
December 31st. So, the next slides, which I will leave for
your reference relate to some resources that we have noted, Deloitte Center for Financial
Reporting and so on and then as I mentioned Appendix A goes through those amendments that
are effective for 2015 fiscal year end and then Appendix B gets into some of the amendments
or the amendments that are effective starting in January 2016. So, certainly probably a
topic of future webcast for us to talk about those 2016 amendments that will affect 2016
year end. So, Jon, I think I will turn it back to you at this point.
Okay thanks Kerry. Safe to say that accounting and financial reporting are not static, they
are always changing. Thanks again to our speakers, Kerry Danyluk and Alexia Donoghue. I would
also like to thank our behind the scenes team, Kiran Kullar, An Lam, Elise Beckles and Allan
Kirkpatrick. We hope that you found this webcast helpful and informative. If you have any questions
or feedback, please reach out to your Deloitte partner or other Deloitte contact. If you
would like additional information, please visit our website at www.deloitte.ca and to
all of you viewing our webcast, thank you for joining us. This concludes our webcast
bringing clarity to an IFRS world - IFRS quarterly technical update.