A U.S. Manager's Guide to Differences Between IFRS and U.S. GAAP

A U.S. Manager’s
Guide to Differences
Between IFRS and
U.S. GAAP
B Y S U S A N B . H U G H E S , P H . D . , C P A , A N D J A M E S F. S A N D E R , P H . D . , C P A
WITH THE GREATER LIKELIHOOD THAT YOU WILL FACE SITUATIONS THAT REQUIRE AN
UNDERSTANDING OF THE DIFFERENCES BETWEEN U.S. GAAP AND IFRS,
THE ODDS INCREASE THAT YOU WILL ALSO HAVE TO BE ABLE TO ESTIMATE THE IMPACT
OF THESE DIFFERENCES.
EXECUTIVE SUMMARY International Financial Reporting Standards (IFRS) are now required for consolidated finan-
cial reports for all European Union exchange-listed companies. Officials estimated that for 2005, the initial year of EU
adoption, 8,000 financial statements were prepared in accordance with IFRS for the first time. Other countries have
also adopted IFRS or IFRS-equivalent financial reporting standards. IFRS differ from U.S. Generally Accepted
Accounting Principles (GAAP) in many key areas. The International Accounting Standards Board (IASB) and the
Financial Accounting Standards Board (FASB) are working on various convergence projects designed to reduce or
eliminate differences between the two sets of reporting standards. But existing differences will likely continue for at
least the next two years, and, for many accounting topics, differences are likely to last much longer. This article high-
lights the 20 convergence projects and summarizes the differences between the two sets of standards. In addition, dif-
ferences in three topics that are not included in the convergence efforts are identified. Differences between IFRS and
U.S. GAAP found in actual EU company Form 20-F filings are used to illustrate the impact of the reporting-standard
differences.
Accountants know that financial reporting ing Standards Board (IASB). The European Commis-
standards differ by country or region. In
sion’s adoption of IFRS for EU public company consoli-
the United States, financial accountants,
dated reports in 2005 required many preparers, auditors,
auditors, and analysts are very familiar
and analysts to become familiar with the content and
with U.S. GAAP. Accountants and auditors
application of IFRS. Standards similar to IFRS were
in other countries may be well-versed in their home-
required in Australia for the first time in 2005 as well. It
country GAAP, or they may be familiar with the
has been estimated that, during that year, 8,000 addi-
requirements of International Financial Reporting Stan-
tional financial statements were based on IFRS. This
dards (IFRS) developed by the International Account-
number will continue to grow as more countries adopt
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IFRS or IFRS-equivalent financial reporting standards.
2008. See Table 1 for a list of the short-term conver-
Canada, for example, is expected to adopt IFRS effec-
gence projects. The table provides information on
tive January 1, 2011.1
which Board is examining the topic, the underlying dif-
In today’s global business environment, it is likely
ferences between IFRS and U.S. GAAP, and the status
that U.S. businesses have customers, suppliers, or
of the project as of July 2007.4
potential acquisition candidates that prepare their finan-
As indicated in Table 1, three of the short-term con-
cial statements in accordance with IFRS. To evaluate
vergence projects have been completed: IFRS 8,
the financial condition and net income of these compa-
“Operating Segments,” was issued by the IASB in
nies appropriately, accountants familiar with U.S. GAAP
2006; Statement of Financial Accounting Standards
need to understand where U.S. GAAP and IFRS differ
(SFAS) No. 159, “The Fair Value Option for Financial
and be able to estimate the potential impact of these
Assets and Financial Liabilities—Including an amend-
differences. We will look at current differences between
ment of FASB Statement No. 115,” was issued by the
U.S. GAAP and IFRS using three steps:
FASB in 2007; and Revised IAS 23, “Borrowing Costs,”
1. The FASB and IASB identified short- and long-term
was issued by the IASB in 2007. Completion of these
convergence projects in their 2006 “Roadmap for
projects indicates that significant accounting differences
Convergence.”2 The accounting topics mentioned in
in these topics no longer exist. For the six ongoing proj-
these convergence projects are listed in two tables,
ects, the project status and key differences column of
and key differences between IFRS and U.S. GAAP
Table 1 describes the existing points of divergence
are provided.
between IFRS and U.S. GAAP, and it provides the
2. A few additional accounting topics not addressed by
expected timetable for each project. Exposure drafts are
either convergence project are noted, and key differ-
expected for three of the projects (income taxes, joint
ences are highlighted.
ventures, and subsequent events) by the first quarter of
3. The actual impact of the key differences on net
2008. Neither the FASB nor the IASB website lists the
income is illustrated using Form 20-F reconciliations
anticipated work schedule for projects related to impair-
of IFRS-based net income compared to that comput-
ments or research and development. The IASB website
ed using U.S. GAAP.
indicates that work on government grants is deferred
In 2006, the IASB announced that no major changes
until other projects are completed.
in IFRS will occur before 2009.3 The implementation
Long-term Convergence Projects. The Boards identi-
dates for new standards adopted during the next two
fied 11 long-term “areas of focus” that will be complet-
years will be delayed until then. This means that even
ed or in process by the end of 2008. Table 2 lists the
if differences between the two sets of accounting stan-
long-term projects in the order in which they were
dards are resolved through the FASB and IASB conver-
announced, details the progress expected by 2008, and
gence projects, important differences in the existing
provides key differences between the two Boards’ stan-
financial reporting standards will continue for at least
dards.5 The first seven topics were on the agendas of
the next few years. There are other differences
both Boards when the Roadmap for Convergence was
between the two sets of financial reporting standards
announced; the last four topics were not on the active
that are not included in the convergence projects, and
agendas then. While the Boards anticipate issuing con-
these differences may continue to exist indefinitely.
verged standards in the area of business combinations
during 2007 and converged guidance on measuring fair
S H O R T- A N D L O N G - T E R M
values during 2008, the other topic areas are in prelimi-
C O N V E R G E N C E P R O J E C T S
nary stages of development.
Short-term Convergence Projects. The Boards are
Together, the short- and long-term lists include 20
working individually and jointly on nine short-term
different reporting areas. Differences in three of the
convergence projects. The goal is to complete work on
areas have been resolved (fair-value option, segment
these specific standard-setting projects by the end of
reporting, and borrowing costs). One or both Boards
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Table 1: SHORT-TERM CONVERGENCE PROJECTS
TOPIC
EXAMINED BY
PROJECT STATUS AND KEY DIFFERENCES
Segment reporting
IASB
Resolved. IFRS 8, “Operating Segments,” issued November 2006.
Fair value option, including
FASB
Resolved. SFAS No. 159, “The Fair Value Option for Financial Assets and Financial
investment properties
Liabilities,” issued February 2007.
Borrowing costs
IASB
Resolved. Revised IAS 23, “Borrowing Costs,” issued March 29, 2007.
Government grants
IASB
Work on this project has been deferred until after the conclusion of other projects.
Impairment
Joint
IFRS base value in use on future discounted cash flows; U.S. GAAP uses the undiscounted
cash flows to determine if impairment occurred. Goodwill and indefinite intangibles are
tested for impairment at the reporting-unit level for U.S. GAAP and at the level of the
cash-generating unit for IFRS. Differences also exist in determining if goodwill is impaired.
U.S. GAAP requires a two-step method; IFRS use a one-step method. Similar to the
treatment of inventory write-downs, U.S. GAAP prohibits the reversal of impairment
write-downs; IFRS require recognition of reversals except for goodwill.
Income tax
Joint
The most obvious difference between IFRS and U.S. GAAP is IFRS’s treatment of all deferred
tax assets and liabilities as noncurrent. Rate differences also are common, as are
differences in treatment between tax effects charged directly to equity (IFRS) and only to
operating income (U.S. GAAP). Joint exposure draft expected Q4 2007.
Joint ventures
IASB
U.S. GAAP requires use of the equity method; IFRS allow either the equity method or
proportional consolidation. IASB Exposure Draft expected Q3 2007; IFRS expected H2 2008.
Research and development
FASB
IFRS allow the capitalization of development costs; U.S. GAAP requires these to be
expensed except when they apply to internal software and website costs.
Subsequent events
FASB
The FASB’s efforts focus on the applicable date through which subsequent events should
be measured and issues pertaining to the reissuance of the financial statements.
Exposure draft expected Q1 2008.
For updated information on the status of these projects, please refer to www.iasb.org/Current+Projects/IASB+Projects/IASB+Work+Plan.htm
and www.fasb.org/project. Information included in Table 1 reflects the information on the two websites as of July 19, 2007.
have indicated that differences in business combina-
reversal of inventory write-downs under certain condi-
tions and measuring fair values should be resolved no
tions, whereas reversals are prohibited under U.S.
later than 2008. Even if the two Boards are able to com-
GAAP.
plete the anticipated work on schedule, differences
Property, Plant, and Equipment—The most obvious
between IFRS and U.S. GAAP will continue for many
and significant difference is that IFRS allows compa-
years in those topics for which only the due-process
nies to revalue property, plant, and equipment to fair
documents or decisions on scope and timing are antici-
value while U.S. GAAP relies on historic cost.
pated by 2008.
Share-based Payments—Differences exist in the treat-
ments of volatility, the measurement date, and the
D I F F E R E N C E S I N OT H E R R E P O R T I N G A R E A S
determination of expense when awards are modified.
Some noteworthy differences between the reporting
standards are not addressed by either the short- or long-
E X A M P L E S O F C O M PA N Y D I F F E R E N C E S
term convergence project. These differences that affect
B E T W E E N I F R S A N D U . S . G A A P
many industries include:
N E T I N C O M E S
Inventory—Two key differences exist in the area of
Some differences between IFRS and U.S. GAAP result
inventory valuation. First, IFRS prohibits the use of the
in immaterial or small differences between their income
LIFO (Last-in, First-out) inventory valuation method
calculations, while others result in significant changes in
allowed under U.S. GAAP. Second, IFRS requires the
net income. One way to determine the impact of the
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Table 2: LONG-TERM CONVERGENCE PROJECTS
PROGRESS EXPECTED
TOPIC
BY 2008
KEY DIFFERENCES
Business combinations
Converged standards:
Differences exist in the valuation dates, determination of the minority interest,
IFRS/SFAS due Q3 2007
treatment of in-process research and development, and treatment of
“negative” goodwill. Differences will continue to exist through 2008 as the
new SFAS (and IFRS) is effective for years beginning after December 15, 2008.
Consolidations
Due-process documents:
U.S. GAAP relies upon majority ownership to determine consolidation status;
discussion paper due H1 2008
IFRS rely upon control. Differences also result from the application of
FIN No. 46R under U.S. GAAP.
Fair value measurement
Converged guidance: roundtable
The SFAS definition differs from IFRS in definitions of the relevant price,
guidance
expected Q3 2007; exposure
the parties, and treatment of liabilities.
draft due H2 2008
Liabilities and equity
Due-process documents:
The objective is to develop a comprehensive standard of reporting for
distinctions
joint issue of preliminary
financial instruments with characteristics of equities, liabilities, equities and
views due Q3 2007
liabilities, and assets.
Financial statement
Due-process documents:
Support for a single statement of comprehensive income seems to be greater
presentation (formerly
discussion paper expected
among U.S.-based users of financial information than among international
known as performance
Q4 2007
users.
reporting)
Post-retirement benefits
Due-process documents:
Differences result from the treatment of benefit termination, curtailments of
(including pensions)
discussion paper expected
benefit plans, the treatment of actuarial gains and losses, and other plan
Q4 2007
considerations.
Revenue recognition
Due-process documents:
U.S. GAAP includes detailed, specific industry guidance.
discussion paper expected
Q1 2008
Derecognition
Due-process documents
Differences exist in rates and the provision to adjust rates at the end of each
accounting period.
Financial instruments
Due-process documents:
IFRS allow the reversal of impairment losses previously recognized; this
discussion paper expected
treatment is prohibited under U.S. GAAP. Differences exist in the types of
Q4 2007
transactions that qualify for hedge accounting, the timing of impairment loss
recognition, use of qualifying SPEs, and other differences.
Intangible assets
Agenda decision expected
IFRS allow the upward revaluation of intangible assets when an active
Q4 2007
market exists; however, upward revaluation is not allowed under U.S. GAAP.
Leases
Due-process documents:
Differences occur in the treatment of gains on sale and leaseback
discussion paper/preliminary
transactions that result in an operating lease. Under U.S. GAAP, the gain is
views expected H1 2008
amortized over the life of the lease, but IFRS recognize the gain at the time
of the sale and leaseback.
For updated information on the status of these projects, please refer to www.iasb.org/Current+Projects/IASB+Projects/IASB+Work+Plan.htm
and www.fasb.org/project. Information included in Table 2 reflects the information on the two websites as of
July 19, 2007.
differences is to apply both sets of financial reporting
20-Fs filed with the SEC.
standards to the same underlying financial information.
Form 20-Fs are filed on an annual basis by foreign
U.S. users of IFRS-based financial reports may find
private issuers with securities traded on U.S. markets
themselves doing just that to derive comparative U.S.
and exchanges. Foreign private issuers are defined as
GAAP results to evaluate potential investments. Anoth-
those companies in which the majority of shareholders
er way to identify where significant differences exist
and officers are located outside the United States. Oth-
between IFRS and U.S. GAAP is to review company-
er foreign companies with securities traded on U.S.
prepared reconciliations of IFRS to U.S. GAAP net
markets and exchanges file Form 10-K. Companies fil-
income and equity. These can be found in some Form
ing Form 10-K must prepare financial statements in
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accordance with U.S. GAAP. Companies filing Form
to topics included in the short- and long-term conver-
20-F may submit their financial statements in accor-
gence projects and areas not included in the conver-
dance with U.S. GAAP or in accordance with non-U.S.
gence projects.
GAAP. If non-U.S. GAAP is used (for example, if the
Reconciling items included in the long-term conver-
company prepares its financial statements in accordance
gence projects resulted in income-reducing adjustments
with IFRS), the company must then reconcile income
related to pensions and other post-retirement benefits
and equity determined under that basis of accounting
(four companies), business combinations (three compa-
to the amounts determined under U.S. GAAP. The
nies), intangible assets (two companies), and revenue
20-F reconciliations of IFRS to U.S. GAAP net income
recognition (one company). Two companies included
and equity clearly indicate where differences between
reconciling items related to financial instruments: In
IFRS and U.S. GAAP occur. The reconciliations also
one case, income was increased, and, in the other,
provide explanations for each of the reconciling items,
income was reduced.
allowing readers to determine if the differences will
Among the nine short-term convergence project top-
recur on an annual basis or are a one-time occurrence.
ics, we found that only the topic of income-tax effects
On June 21, 2007, the Securities & Exchange Com-
resulted in significant reconciling items, and that item is
mission (SEC) reiterated the possibility of allowing U.S.
seen in the reconciliations of two companies. Within the
companies to file regulatory reports in accordance with
topics for which no convergence projects are planned,
IFRS.6 These developments further emphasize the
property, plant, and equipment reporting differences
need for U.S. accountants to familiarize themselves
resulted in a 31.3% reduction in IFRS net income for
with the differences between the two sets of standards.
Intercontinental Hotels, and differences in reporting
We selected 12 EU company Form 20-Fs filed in
share-based payments increased Alcatel’s IFRS net
accordance with IFRS for 2005 to illustrate where sig-
income by 7.4%. Although this reconciling item is less
nificant differences occur between IFRS and U.S.
than the 10% of IFRS net income we used as a cutoff in
GAAP.7 Table 3 lists each of the sampled companies
identifying other reconciling items, we show it to illus-
and summarizes the net income determined under
trate that companies include reconciling items related
IFRS and U.S. GAAP, the difference in the incomes,
to many topics that could have a substantial impact on
and the relative size of the difference as a percentage of
net income.
IFRS net income. We reviewed the individual reconcil-
To understand the net income effect of differences in
ing items and identified those greater than 10% of
U.S. GAAP and IFRS, it is also important to consider
IFRS net income. These reconciling items are also
reconciling item effects by company. Seven of the 12
shown in Table 3. The reconciling items are classified
companies included in Table 3 had only one significant
as relating to a long-term convergence project topic
reconciling item. The other five companies had a vari-
(LT), a short-term project topic (ST), or a topic not
ety of reconciling items. When offsetting items exist,
addressed by either convergence project (NA).
the net change in income from IFRS to U.S. GAAP
As shown in Table 3, converting IFRS net income to
may not reveal significant differences between the two
its U.S. GAAP equivalent generally reduces net income.
sets of accounting standards.
Specifically, it decreased the net income of nine compa-
For example, Novartis reported IFRS net income (in
nies, increased the net income of one company, and
millions) of $6,141 and U.S. GAAP net income of
increased the net loss of two. The change in net income
$5,190, a difference of $951 (16% of IFRS net income).
ranged from a decrease of $951 million for Novartis to
€
Accounting for intangible assets resulted in a $1,248
an increase of 16 million for Campagnie Generale de
reconciling item (20.2% of IFRS net income). No other
Geophysique. When the change in net income is divid-
significant reconciling items were included for 2006. A
ed by IFRS net income, the effects of the change range
different pattern is seen in British Airways’s March 31,
from a decrease of 67.2% to an increase of 206.4%. The
2006, reconciliation.8 IFRS net income was reported (in
changes occurred because of reconciling items related
millions of British pounds) as £451, U.S. GAAP net
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28.2
22.8
-5.4
-8.9
-19.1%
-31.6%
Group
12/31/05 million €
SCG Carbon
-574
-721
-147
-63 1.0%
-25.6%
-1
Thomson
12/31/05 million €
-105
-213
-108
-84
-102.9%
-80.0%
Sorono
12/31/05 million $
462
374
-88
-78
-19.0%
-16.9%
12/31/05
Reed Elsevier
6,141
5,190
-951
-15.5%
-1,238 -20.2%
Group
12/31/05 million $
The Novartis
496
355
-141
-155
-28.4%
-31.3%
Hotels
12/31/05
Intercontinental
390
208
-182
-176
-46.7%
-45.1%
Imperial Chemicals
12/31/05
Industries PLC
-7.8
8.3
16.1
22.4
206.4%
287.2%
12/31/05 million €
Campagnie Generale de Geophysique
451
148
-303
-219
-281
233
-67.2%
-48.6%
-62.3%
51.7%
British Airways
3/31/06
181 .3%
1,595
1,327
-268
-450
-16.8%
-28.2%
11
Bayer AG
12/31/05 million €
4,706
3,884
-822
-17.5%
-1,019 -21.7%
PLC
12/31/05 million $
AstraZeneca
903
1
8
82
1,101
-198
-1
7.4%
-18.0%
-10.7%
Alcatel
12/31/05 million €

revaluation
IFRS TO U.S. GAAP NET DIFFERENCES AND KEY RECONCILING ITEMS
Company Name
For the year ended
equipment
and
f
ects
T
able 3:
Key Reconciling Items
ef
tax
,
plant,
Net income attributable to the equity holders of the parent according to IFRS
Net income according to U.S. GAAP
Net reconciling items
Percent of IFRS net income
Business combinations and amortization of goodwill (Consolidations, Long-term convergence) Percent of IFRS net income
Financial instruments (Derivatives, Long-term convergence) Percent of IFRS net income Intangible assets Percent of IFRS net income Pensions Percent of IFRS net income Revenue recognition Percent of IFRS net income Income Percent of IFRS net income
Property Percent of IFRS net income Share-based payments Percent of IFRS net income
indicates a short-term convergence project item indicates a long-term convergence project item indicates that the topic is not addressed by either convergence project

ST LT NA
LT
LT
LT
LT
LT
ST
NA
NA
Project
Convergence
Convergence Project Key:
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income as £148, resulting in a difference of £303 (67.2%
is not a complete checklist, it could help them identify
of IFRS net income). Three significant items were
factors that contribute to significant reporting differ-
included in the reconciliation: Differences in reporting
ences in their global operations.
financial instruments reduced income by £219, differ-
1. Has the company made a significant acquisition dur-
ences in pensions reduced income by £281, and
ing the past year? What is the IFRS impact of the
income-tax effects increased IFRS net income by £233.
acquisition compared to the impact when measured
The reconciling items included in Table 3 also indi-
using U.S. GAAP?
cate that reconciling items pertaining to a specific topic
2. Has the company elected to revalue property, plant,
may increase IFRS net income for one company and
and equipment under IFRS? Check the notes for
decrease it for another. These mixed effects make it
disclosure.
difficult to anticipate whether the presence of these
3. Does the company utilize financial instruments?
items will increase or decrease IFRS net income.
Again, check the notes, and estimate the reduction
Therefore, the effects of reporting differences in these
in U.S. GAAP net income.
topic areas must be considered on a company-specific
4. Be clear about the standards governing revenue
basis.
recognition. IFRS do not require companies to rec-
ognize up-front fees over the life of a contract, but
D I S C U S S I O N A N D C H E C K L I S T
U.S. GAAP does. What is the potential need for rev-
Accountants in the United States are increasingly more
enue adjustment?
likely to encounter situations with customers, suppliers,
5. IFRS do not allow the use of LIFO to estimate
or potential acquisition candidates that require both an
inventory cost. This restriction may actually simplify
understanding of where U.S. GAAP and IFRS differ
a financial evaluation or comparison of companies
and the ability to estimate the potential impact of these
because the restriction eliminates the possible need
differences. Current differences between U.S. GAAP
to adjust LIFO inventory amounts to First-in, First-
and IFRS, as well as examples taken from Form 20-F
out (FIFO) values for foreign companies.
reconciliations, illustrate the potential magnitude of the
6. Disclosures under IFRS are likely to be less compre-
resulting income differences.
hensive than under U.S. GAAP. When dealing with
In our small sample of 12 Form 20-F reconciliations,
disclosures under IFRS, plan to look through multi-
we identified material reconciling items that correspond
ple notes, and be ready to piece together fragmented
with five long-term convergence project topics, one
disclosures from multiple locations in order to obtain
short-term convergence project item, and two topics not
the complete disclosure about a topic.9
included in the convergence projects. Work on most of
Readers should keep in mind that the Boards and the
the convergence project topics is in the initial phase, so
SEC have acknowledged that it will take many years to
most reconciling items will continue to exist through at
achieve a common set of high-quality standards. Taking
least 2008, and some differences may persist much
the time to identify where differences occur between
longer. When you combine the evidence that differ-
the two sets of standards and the impact of those differ-
ences may be material with the understanding that
ences should result in better decision making for many
income differences are likely to persist for several years,
years to come. s
you see why U.S. accountants should understand where
differences are likely to occur and why they should
Susan B. Hughes, Ph.D., CPA, is an associate professor of
adjust for these differences when evaluating or compar-
accounting at the University of Vermont, Burlington. You
ing companies that report under the two different sets
can reach Susan at shughes@bsad.uvm.edu.
of accounting standards.
When evaluating or comparing companies that use
James F. Sander, Ph.D., CPA, is an associate professor of
different sets of reporting standards, accountants might
accounting at Butler University, Indianapolis, Ind. You can
want to consider the following questions. Although this
reach James at jsander@butler.edu.
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E N D N OT E S
1 Information on Canada’s planned adoption of IFRS can be
found in “Implementing Plan for Incorporating International
Financial Reporting Standards into Canadian GAAP,” www.acsb
canada.org/client_asset/document/3/2/7/3/5/document_8
B452E12-FAF5-7113-C4CB8F89B38BC6F8.pdf?sfgdata=4.
2 International Accounting Standards Board and the Financial
Accounting Standards Board, Memorandum of Understanding
between the FASB and the IASB: A Roadmap for Convergence between
IFRSs and U.S. GAAP—2006-2008, February 27, 2006.
3 International Accounting Standards Board, “No New Major
Standards to be Effective before 2009,” 2006. www.iasb.org/
Current+Projects/No+new+major+standards+to+be+effective+
before+2009.htm?m=print.
4 The status of the short- and long-term convergence projects
included in this article was last updated on July 19, 2007. Read-
ers should access the Current Projects link on the IASB
(www.iasb.org) and the FASB (www.fasb.org) websites to identi-
fy later progress on the projects.
5 See Deloitte, “IFRSs and U.S. GAAP: A Pocket Companion,”
March 2007, for more detail about the differences between
IFRS and U.S. GAAP. www.IASPLUS.com/dttpubs/pubs.htm#
mar2007.
6 Kara Scannell and David Reilly, “Foreign Affair: Is End Near
for ‘U.S. Only’ Accounting?” The Wall Street Journal, June 21,
2007, C1-2. See also Securities & Exchange Commission
Releases Nos. 33-8818; 34-55998; International Series Release
No. 1302; File No. S7-13-07, Acceptance from Foreign Private
Issuers of Financial Statements Prepared in Accordance with Interna-
tional Financial Reporting Standards without Reconciliation to U.S.
GAAP.
7 Readers interested in locating additional 20-F reconciliations
should refer to Staff Comments on Annual Reports Containing
Financial Statements Prepared for the First Time on the Basis
of International Financial Reporting Standards (www.sec.gov/
divisions/corpfin/ifrs_reviews.htm) or to Susan B. Hughes,
“Using Form 20-F Reconciliations to Internationalize an
Accounting Course,” Accounting Education, 2007.
8 British Airways’s year-end is March 31, so those statements are
as of March 31, 2006.
9 A summary of the SEC Staff Comments pertaining to the first-
year review of IFRS-based financial statement disclosures can
be found at www.sec.gov/divisions/corpfin/ifrs_staffobservations.
htm.
M A N A G E M E N T A C C O U N T I N G Q U A R T E R L Y
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