SEC Comment Letters on Foreign Private Issuers Using IFRSs (Second Edition) — Updated December 2009 |
This revised edition of SEC Comment Letters on Foreign Private Issuers Using IFRSs — A Closer Look reflects new topics and updates existing topics to reflect new areas that the SEC staff has commented on since the release of the first edition in January 2008. The SEC staff has continued to issue comments on topics included in the first edition of this publication, such as financial instruments, financial statement presentation, revenue recognition, provisions, and income taxes. This second edition not only provides revised coverage of these topics but also adds four new topics: share-based payment, business combinations, earnings per share, and intangible assets. In addition to an overall analysis of the nature and types of SEC staff comments, this publication includes extracts from actual comment letters, accompanied by a discussion of the topic involved as well as forward-looking considerations.
This publication will be particularly useful both 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 given the use of IFRSs around the world and the increased likelihood that the SEC will eventually require the use of IFRSs for U.S. registrants.
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