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SEC Comment Letters on Foreign Private Issuers Using IFRSs (Third Edition)

March 2012


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This new release in Deloitte’s SEC Comment Letter series provides insight into the topics upon which the Securities and Exchange Commission (SEC) staff has focused in its reviews of foreign private issuers’ periodic filings. Such items include financial instruments, presentation of financial statements (including the statement of cash flows), revenue recognition and related costs, segment reporting, income taxes, provisions and contingent liabilities, business combinations, intangible assets, and disclosures in other sections of the periodic filings, including operating and financial review and prospects.

The third edition includes discussions of the following new areas of frequent SEC comment: first-time adoption of International Financial Reporting Standards (IFRSs); impairment of assets; consolidated financial statements, investments in associates, and interests in joint ventures; property, plant, and equipment; employee benefits; discontinued operations; and other disclosure topics, such as risk disclosures, non-GAAP financial measures, controls and procedures, and guarantor financial statements.

This publication will be particularly useful for companies that are currently using IFRSs and those that are looking to learn more about IFRSs. Understanding the SEC staff’s comments has become increasingly important as more countries continue to adopt IFRSs around the world.

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