Are you ready for the new revenue recognition standard to go live? For companies in many industries, implementing this standard is likely to be more time-consuming, complex and costly than management expects. Here’s an overview of the changes that are coming soon to your income statement and an IRS notice requesting comments about how the standard will affect income tax reporting.
A Major Shift
In May 2014, the Financial Accounting Standards Board (FASB) published Accounting Standards Update (ASU) No. 2014-09, Revenue from Contracts with Customers. The standard converged the rules for recognizing revenue under U.S. Generally Accepted Accounting Principles (GAAP) with new accounting rules published by the International Accounting Standards Board (IASB).
The FASB’s revenue standard is the result of more than a decade of work with the IASB to produce a single method for companies worldwide to calculate their revenue. It scraps about 180 pieces of business- and transaction-specific guidelines in U.S. GAAP and calls for a principles-based approach. Under the converged standard, companies must follow a five-step procedure for recognizing revenue:
In some cases, this will result in earlier revenue recognition than in current practice, because the new standard will require companies to estimate the effects of sales incentives, discounts and warranties.
Public companies must comply with the new revenue guidance in 2018. Private companies have an extra year for implementation. The standard is expected to create major accounting changes in certain industries, including software and telecommunications. In other sectors, such as retail, the change isn’t expected to be as dramatic. The shift from rules-based accounting to more principles-based guidance also is expected to be a significant cultural shift for U.S. companies and their accountants.
FASB Concerns
Recently, some FASB members have expressed concerns that the implementation process will require tremendous costs, even for the industries facing relatively modest changes. Member Lawrence Smith even voiced regrets about approving the changes to the revenue recognition guidance.
Smith said that if the FASB had known what they know today about the overall cost of implementing the new standard when they added it to their agenda, they might have taken a different approach. As he now sees it, they might have better served investors and other constituents if they had explored targeted improvements to the existing guidance, instead of completely rewriting the standards.
IRS Issues
Implementation issues on revenue recognition cross over into tax reporting. While the new revenue recognition standard is a significant change from current accounting standards, the income recognition rules for tax purposes currently remain unchanged.
Section 451 of the tax code requires a taxpayer to recognize income under the “all events” test when it: 1) has a fixed right to receive the income, and 2) can determine the amount with reasonable accuracy. Implementation of the new revenue recognition standard may create or increase differences between accounting and tax rules.
On March 28, the IRS issued Notice 2017-17 to request comments regarding the changes companies expect because of the new revenue standard. Comments are specifically requested on the following issues related to conformity between the new accounting standards and the tax rules:
The IRS also wants to know if there are any industry- or transaction-specific issues that should be addressed in future IRS guidance.
Change in Reporting Method
The IRS notice also seeks comments on a proposed revenue procedure for getting automatic consent to a change of accounting method. It’s intended to address situations where a change in accounting method is sought in the same year of adoption as the FASB revenue recognition standard.
Under the current tax rules, a taxpayer generally must obtain consent from the IRS to change a tax accounting method by filing IRS Form 3115, “Application for Change in Accounting Method,” and submitting detailed information about the change. To alleviate the administrative burden, the IRS created a list of “automatic” method changes whereby the taxpayer is deemed to have the consent of the IRS to change its accounting method if the taxpayer is within the scope of a revenue procedure and any related guidance for the specific method change. Specifically, the IRS notice asks:
Comments to IRS Notice 2017-17 are due by July 24. The IRS previously issued a notice with similar questions in 2015, but very few comment letters were received. With the implementation date just months away for many businesses, they are hoping for a better response rate this time around.
Need Help?
Many companies are struggling with the nitty-gritty details of adopting the landmark revenue recognition rules. The recent IRS notice demonstrates that the effects of this standard cross over into other business functions, including income tax reporting. If you have questions or concerns about the new guidance, talk to your Armanino professional.
AICPA Seeks Feedback on Recently Drafted Interpretive Guides
Implementing the new revenue recognition standard is expected to be more time-consuming for certain industries. On March 31, the AICPA’s Financial Reporting Executive Committee (FinREC) published working drafts of interpretive guidance for the new standard. The working drafts provide industry-specific guidance for:
The draft implementation issues were produced by task forces assigned by FinREC to develop guidance for the next edition of the Audit and Accounting Guide (AAG): Revenue Recognition. Comments are due by June 1.
May 30, 2017