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1、 Financial Reporting in Different Countries Friday, September 30, 20221 Financial Reporting in DiffLearning Objectives Explain the most important domestic and international influences on financial reporting in different countries .Describe the local GAAP in different countries.Explain the general ch

2、aracteristic of accounting in different countries.Outline the principal differences between country accounting rules and IFRSs.Friday, September 30, 20222Learning Objectives ExplainTo group countries according to the common elements and distinctive characteristics of their financial accounting syste

3、ms.Friday, September 30, 20223Review of selected classification studiesMuller(1967) identified the following four approaches to accounting development in Western market-oriented economies.Under the macroeconomic approachUnder the microeconomic approachUnder the independent discipline approachUnder t

4、he uniform approachTo group countries according tFriday, September 30, 20224Review of selected classification studiesTuesday, September 27, 20224ReFriday, September 30, 20225Review of selected classification studiesNobes classification is consistent with certain environment factors discussed earlier

5、 in Chapter 1.OthersLegal Systems: Common Laws vs. Code Law AccountingPractice Systems: Fair Presentation vs. Legal Compliance AccountingGrays accounting values and Hofstedes cultural dimensionsTuesday, September 27, 20225ReThis chapter more closely examines accounting in a few selected countries.(F

6、rance, Germany, Dutch, Japanese, U.K. ,U.S.A) .What- characteristics Why- environmental factors How-regulations, convergenceFriday, September 30, 20226Review of selected classification studiesThis chapter more closely exaIn this sectionThere is an examination of the regulatory framework, especially

7、the Securities and Exchange Commission (SEC) which demands the worlds most extensive disclosures from public companies. Then examines the standards-setting process, leading to consideration of the conceptual framework and the detailed US GAAP components.There is a comparison with IASB requirements,

8、differences from IFRS.Friday, September 30, 20227American AccountingIn this sectionTuesday, SeptemWhat-The Characteristics of American AccountingU.S. influenceBusiness practice,Pragmatic,British originMicro-uniform Friday, September 30, 20228American AccountingWhat-The Characteristics of AU.S. influ

9、enceUS influence on the accounting of other countries and on international standards has been considerable.However, from 2001,with the creation of the International Accounting Standards Board(IASB) coinciding closely with a series of accounting scandals in the United States, US accounting has been i

10、nfluenced form outside, especially by plans for convergence with IFRS.Friday, September 30, 20229American AccountingU.S. influenceTuesday, SeptembBritish originUS accounting was originally an export from the United Kingdom, like the American language and the American legal system.The United States a

11、nd the United Kingdom are reasonably similar in world context, although regulation of accounting differs.If countries are to be classified, the similarities suggest that the United States and the United Kingdom are in the same family.Friday, September 30, 202210American AccountingBritish originTuesd

12、ay, Septemb30 九月 2022What-The Characteristics of American AccountingDual regulatory structureSEC FASBReorganized (2002)No general legal requirement for corporation financial statementsState law, not federal lawAnnual audit and financial reporting requirements exist at the federal level by SECRoles o

13、f AICPA-FASBAmerican Accounting27 九月 2022What-The CharacteriWhy specific environmental factorsLawsThe securities and Exchange CommissionThe United States Congress Friday, September 30, 202212American AccountingWhy specific environmental fa Laws The United States is a federation of individual states,

14、 each of which has its own legislative body with extensive powers to control business activity and levy taxes within its own boundaries. The most important regulations for the control of dealing in securities are enforced at the federal level under the Securities Act of 1933 and the Securities Excha

15、nge Act of 1934.Neither these statutes nor any others contain detailed provisions relating to financial reporting.Friday, September 30, 202213American Accounting LawsTuesday, September 27, 2LawsNeither these statutes nor any others contain detailed provisions relating to financial reporting.The Unit

16、ed States has no statutory requirements for accounting in a form that is comparable to the accounting section of the Companies Acts in the UK or similar regulations in other EU countries.Friday, September 30, 202214American AccountingLawsTuesday, September 27, 202Laws The federal securities legislat

17、ion established the SEC in 1934 to administer the securities regulations. It requires publication and receives registration of prospectuses and periodic financial reports. It also has the power to prescribe the methods to be followed in the preparation of financial reports and to prescribe the form

18、and content of those reports.Friday, September 30, 202215American AccountingLawsTuesday, September 27, 202 The securities and Exchange Commission The commission comprises five members appointed by the President of the United States and act as an independent regulatory body with quasi-judicial powers

19、.It has issued a large number of statements on accounting matters.However, these have related mainly to the details of registration rather than to accounting standards.Friday, September 30, 202216American Accounting The securities and Exchange C The securities and Exchange CommissionHowever, the SEC

20、 has tended to limit the exercise of its accounting standard-setting authority to a supervisory role, permitting and encouraging the private sector, currently through the Financial Accounting Standards Board (FASB), to maintain leadership in the standard-setting process.Friday, September 30, 202217A

21、merican Accounting The securities and Exchange C The securities and Exchange CommissionThe commission sometimes issues instruction on how to do accounting in Accounting Series Release or more recent Financial Reporting Releases. There are also Staff Accounting Bulletins. Friday, September 30, 202218

22、American Accounting The securities and Exchange C The securities and Exchange CommissionThe events of accounting scandals of Enron and WorldCom of 2001/2 and the collapse of Andersen,the Big-5 accounting firm, led to the creation by Congress of the Public Company Accounting Oversight Board(PCAOB),wh

23、ich is overseen by the SEC.Also, the accounting duties of directors and the independence requirements of auditors were increased. Friday, September 30, 202219American Accounting The securities and Exchange CThe United States Congress The US legislative authority the Congresshas occasionally taken a

24、direct interest in accounting matters, although it has usually relied on the SEC to look after the public interest.The action of Congress may be seen as the forerunner of the concern about the neutrality of standards.Friday, September 30, 202220American AccountingThe United States Congress Tue The U

25、nited States Congress The political lobbying on US stand-settingSolomons(1978) ,Zeff(1978,1997) and Mozes(1988) describe a major battle between standard-setters and elements of government on the subject of accounting of stock options.The general topic of political involvement in standard-setting exe

26、mplify the further involvement by Congress on the reform of accounting for business combinations caused by opposition from companies to the banning of pooling accounting.Friday, September 30, 202221American Accounting The United States Congress Tu30 九月 2022How regulate and enforce SEC/FASBSEC-oversi

27、ght, by exception FASB-be perceived, support of public accounting professionAdvantages of dual regulatory structure P166-167American Accounting27 九月 2022How regulate and enf30 九月 2022How regulate and enforce SEC/FASBAccounting is regulated by a private-sector body(FASB), AICPA,another private-sector

28、 body, set auditing standards; but a governmental agency(SEC) underpins the authority of its standards.American AccountingHow Regulate SEC/FASBStock Crash in 1929 and Great DepressionSecurities Act of 1933Securities Exchange Act of 193427 九月 2022How regulate and enf30 九月 2022How regulate and enforce

29、 SEC/FASBSEC has the legal authority to prescribe accounting and reporting standards for public companies but relies on the private sector to set standards.SEC is independent regulatory agency. However, the five fill-time SEC commissioners are appointed by the president and confirmed by the Senate,S

30、EC has only the powers that Congress has granted if by statute. Congress and the president have no direct influence over its policies.Intervened? few exception, economic consequence no bias, neutralityAmerican Accounting27 九月 2022How regulate and enf30 九月 2022How regulate and enforceSEC/FASB SEC aff

31、irms its supports for FASB by indicating that financial statements conforming to standards set by the FASB will be presumed to have substantial authoritative support. P168Accounting standards have generally been developed in the private sector either through the American Institute of Certificated Pu

32、blic Accountants (AICPA) or the Financial Accounting Standards Board(FASB).American Accounting27 九月 2022How regulate and enfHow regulate and enforce SEC/FASB Accounting in the United States is regulated by a private-sector body, the Financial Accounting Standards Board (FASB), but a governmental age

33、ncy, the Securities and Exchange Commission (SEC) underpins the authority of its standardsFriday, September 30, 202226American AccountingHow regulate and enforceTuesdaHow regulate and enforceAICPAUntil 2002, the American Institute of Certified Public Accountants (AICPA), another private-sector body,

34、 set auditing standards. In 2003, the Public Company Accounting Oversight Board decided to set auditing standards itself rather than delegating this task to the AICPA, which had performed the role for over 60 years.Friday, September 30, 202227American AccountingHow regulate and enforceTuesda28Americ

35、an AccountingHow regulate and enforceAICPAEnron and WorldCom scandalsThe Sarbanes-Oxley Act of 2002Public Company Accounting Reform and Investors Protection Act of 2002Significantly expanding U.S. requirements on corporate governance, Disclosure and reporting, and the regulation of the audit profess

36、ion. SEC-Public Company Accounting Oversight Board 公众公司会计监督委员会PCAOB assume the responsibility of setting standards from the AICPA 28American AccountingHow regul29American AccountingHow regulate and enforceAICPAResponsible for the Code of Professional Ethics and disciplined auditors.Independent Audit

37、ors: limit non-audit services, rotate off audits every five yearsAuditors Report covers both the financial statements and internal control. -(COSO) 29American AccountingHow regul30American AccountingHow regulate and enforceCOSOThe Committee of Sponsoring Organizations of The National Commission of F

38、raudulent Financial Reporting 全国虚假财务报告委员会下属的发起人委员会 (通常称Treadway委员会) Sarbanes-Oxley Act Internal Control-Integrated Framework (Treadway,1992) 内部控制一整体框架 Enterprise Risk Management Framework(COSO-ERM,2004) 企业风险管理框架 30American AccountingHow regulFriday, September 30, 202231American AccountingTuesday, Se

39、ptember 27, 202231AFriday, September 30, 202232American AccountingTuesday, September 27, 202232AFriday, September 30, 202233Tuesday, September 27, 202233Friday, September 30, 202234Tuesday, September 27, 202234Friday, September 30, 202235Tuesday, September 27, 202235Friday, September 30, 202236“MANA

40、GEMENT ASSESSMENT OF INTERNAL CONTROLS”Tuesday, September 27, 202236“How regulate and enforceAICPA Independent Auditors The Sarbanes-Oxley prohibits the provision of some non-audit services to audit clients, requires the rotation of audit lead and review partners every five years, and require audits

41、 to report to an audit committee not management.Friday, September 30, 202237American AccountingHow regulate and enforceTuesda30 九月 2022How regulate and enforce SEC American AccountingEstablished by federal governmentAccounting and reporting for public companiesEncouraged private standard-setting bod

42、ySEC requires public companies to adhere to GAAPSEC OversightEnforcement Authority27 九月 2022How regulate and enf30 九月 2022How regulate and enforceFASB Predecessors(AICPA) P168American AccountingCommittee on Accounting Procedures(CAP)会计程序委员会Issued 51 Accounting Research Bulletins (会计研究公报)1939 1958Pro

43、blem-by-problem approach failedAccounting Principles Board(APB)会计原则委员会Issued 31 Accounting Principle Board Opinions (会计原则委员会意见书)1958-1973Wheat Study Group (惠特调研组)recommendations adopted in 1973FASB TrueBlood Report (特鲁布拉德报告) Objective s of Financial ReportingCohesive system27 九月 2022How regulate and

44、 enf30 九月 2022Financial Accounting FoundationSelects members of the FASB (AICPA,%)Funds their activities Exercises general oversight.Financial Accounting Standards BoardFinancial Accounting Standards Advisory CouncilMission to establish and improve standards of financial accounting and reporting.Con

45、sult on major policy issues.How regulate and enforceFASB and GAAP /Wheat Committees recommendations resulted in the creation of a the Financial Accounting Standards Board in 1973.American Accounting27 九月 2022Financial AccountingHow regulate and enforceFASB and GAAPOriginally, GAAP meant what is said

46、; that is ,a set of high-level principles endorsed by respectable companies, auditors and textbooks.However, from the 1930s onwards, rules have gradually been written down. As a result,GAAP is now a large body of instructions: it is not principles but detailed rules, and it is not generally accepted

47、 but written down by bodies approved by the SEC.Friday, September 30, 202241American AccountingHow regulate and enforceTuesdaFriday, September 30, 202242American AccountingHow regulate and enforceFASB and GAAPGAAP comprise all the financial accounting standards, rules, and regulations that must be o

48、bserved in the preparation of financial reports.The SFASs are the major component of GAAP.More voluminous and more detailed than any other country.Rule-based Principle-based(2002-)Tuesday, September 27, 202242AHow regulate and enforceFASB and GAAP In 2001/2, the difference between US rules-based sta

49、ndards and IASB principles based standards was highlighted because of the spectacular collapses of some large companies (e.g. Enron).Friday, September 30, 202243American AccountingHow regulate and enforceTuesdaFriday, September 30, 202244American AccountingHow regulate and enforceFASB and GAAPStatem

50、ents of Financial Accounting Standards (SFAS,财务会计准则公告)Statements of Financial Accounting Concepts (SFAC,财务会计概念公告)Interpretations on Financial Accounting Standard (财务会计准则解释)Tuesday, September 27, 202244A30 九月 2022The FASB has issued six Statements of Financial Accounting Concepts (SFAC) for business

51、enterprises.SFAC No.1 -Objectives of Financial ReportingSFAC No.2 - Qualitative Characteristics of Accounting InformationSFAC No.3 - Elements of Financial Statements (superceded by SFAC No. 6)SFAC No.4 - Non-business OrganizationsSFAC No.5 -Recognition and Measurement in Financial Statements SFAC No

52、.6 - Elements of Financial Statements (replaces SFAC No. 3)SFAC No.7 -Using Cash Flow Information and Present Value in Accounting MeasurementsHow regulate and enforceFASB and GAAPAmerican Accounting27 九月 2022The FASB has issued 30 九月 2022Investment by ownersDistribution to ownersComprehensive income

53、RevenueExpensesGainsLossesSFAC No. 6 defines ten interrelated elements that relate to measuring the performance and financial status of a business enterprise.AssetsLiabilitiesEquity“Moment in Time”“Period of Time”American AccountingHow regulate and enforceFASB and GAAP27 九月 2022Investment by owners3

54、0 九月 2022The Conceptual Framework is comprised of three levels:First Level = Basic ObjectivesSecond Level = Qualitative Characteristics and Basic ElementsThird Level = Recognition and Measurement Concepts.American AccountingHow regulate and enforceFASB and GAAP Appendix P174-17927 九月 2022The Concept

55、ual Frame30 九月 2022Conceptual FrameworkNeedDevelopmentFirst Level: Basic ObjectivesSecond Level: Fundamental ConceptsThird Level: Recognition and MeasurementBasic assumptionsBasic principlesConstraintsQualitative characteristicsBasic elementsConceptual FrameworkAmerican Accounting27 九月 2022Conceptua

56、l FrameworkASSUMPTIONSEconomic entityGoing concernMonetary unitPeriodicityPRINCIPLESHistorical costRevenue recognitionMatchingFull disclosureCONSTRAINTSCost-benefitMaterialityIndustry practiceConservatismELEMENTSAssets, Liabilities, and EquityInvestments by ownersDistribution to ownersComprehensive

57、incomeRevenues and ExpensesGains and LossesTHE Conceptual Framework for Financial ReportingQUALITATIVE CHARACTERISTICSRelevanceReliabilityComparabilityConsistencyOBJECTIVES1. Useful in investment and credit decisions2. Useful in assessing future cash flows3.About enterprise resources, claims to reso

58、urces, and changes in themASSUMPTIONSPRINCIPLESCONSTRAINHierarchy of Accounting QualitiesHierarchy of Accounting QualitFinancial ReportingFriday, September 30, 202251A typical annual financial report of a large US corporation includes the following components: 1. Report of management 2. Report of in

59、dependent auditors 3. Primary financial statements (income statement, balance sheet, statement of cash flows, statement of comprehensive income, statement of changes in stock holders equity) Financial ReportingTuesday, SeFinancial ReportingFriday, September 30, 202252 4. Management discussion and analysis of results of operations and financial condition 5. Disclosure of accounting policies with the most critical imp

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