Comment letters submitted to international accounting standard-setters

Related documents

•   Discussion Paper Extractive Activities (July 19, 2010)

  Comment on the Discussion Paper Extractive Activities (the Paper). Our main comments and suggestions on the issues raised in the Paper are summarised in the attached document. Our responses to the Invitation to Comment questions are set out in the Appendix.
  

•   Exposure Draft ED/2010/4 Fair Value Option for Financial Liabilities (July 15, 2010)

  Comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2010/4 Fair Value Option for Financial Liabilities. We have considered the ED as well as the accompanying draft Basis for Conclusions.

•   Exposure Draft ED/2009/12 - Financial Instruments: Amortised Cost and Impairment (June 9, 2010)

  Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/12 - Financial Instruments: AmortisedCost and Impairment.

•   Exposure Draft ED/2010/1 Measurement of Liabilities in IAS 37 (May 18, 2010)

  Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2010/1 Measurement of Liabilities in IAS 37 (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

•   Exposure Draft ED/2009/6 Management Commentary (February 19, 2010)

  Comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/6 Management Commentary (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

•   Exposure Draft ED/2009/13 Limited Exemption from Comparative IFRS 7 (December 17, 2009) (81.21KB)

  Comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/13 Limited Exemption from Comparative IFRS 7 Disclosures for First-time Adopters (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

•   Review Part 2 Proposals for Enhanced Public Accountability (November 30, 2009) (148.04KB)

  Comment on the IASC Foundation's Consultation Document Part 2 of the Constitution Review - Proposals for Enhanced Public Accountability (the Part 2 Proposals). In the attached letter we offer some general comments on the Part 2 Proposals.  

•   Exposure Draft Improvements to International Financial Reporting Standards (November 24, 2009) (170.76KB)

  Comment letter on the International Accounting Standards Board's (the Board) Exposure Draft Improvements to International Financial Reporting Standards (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

•   Rate Regulated Activities (November 17, 2009) (140 KB)

  Comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/8 Rate-regulated Activities(the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

•   Draft Endorsement Advice and Effects Study Report on IFRS 9 Financial Instruments (132 KB)

  Comment letter submitted November 10, 2009.

•   IFRIC Draft Interpretation D25 Extinguishing Financial Liabilities with Equity Instruments (October 2, 2009) (93.8 KB)

  Grant Thornton International Ltd agrees that IFRS does not provide specific guidance on accounting for transactions in which an entity issues its own equity instruments to extinguish all or part of a financial liability. It also believes there is significant diversity in the accounting for such transactions in practice.

•   Exposure Draft ED/2009/05 - Fair Value Measurement (September 28, 2009) (181 KB)

  Grant Thornton International agrees with the proposed definition of fair value and with much of the supporting guidance. The comment letter outlines concerns with the application of the proposed definition and with some aspects of the detailed guidance.  

•   Exposure Draft 2009/10 Discount Rate for Employee Benefits: Proposed Amendments to IAS 19 (September 24, 2009) (46 KB)

  Grant Thornton International has some concerns regarding the appropriateness of using the yield on high quality corporate bonds as the discount rate, but believes that the ED's proposals are an improvement to IAS 19. It therefore supports the Board's proposal for a fast-track amendment.

•   Exposure Draft ED/2009/07 - Financial Instruments: Classification and Measurement (September 11, 2009) (190 KB)

  Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/07 Financial Instruments: Classification and Measurement (the ED).

•   Exposure Draft ED/2009/9 Classification of Rights Issues - proposed amendment to IAS 32 (September 7, 2009) (110 KB)

  Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/9 Classification of Rights Issues - proposed amendment to IAS 32. We have considered the ED, as well as the accompanying draft Basis for Conclusions.

•   Discussion Paper - Credit Risk in Liability Measurement (August 24, 2009) (125 KB)

  Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Discussion Paper Credit Risk in Liability Measurement (the DP). We have considered the DP along with the accompanying Staff Paper and set out our comments. We welcome the Board's decision to seek views on the role of 'own credit risk' in measuring liabilities. As noted in the DP, this issue has generated considerable comment and controversy. It is also relevant to several of the Board's current projects.

•   Prepayments of a Minimum Funding Requirement - Proposed amendments to IFRIC 14 (July 24, 2009) (95 KB)

  Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board's) Exposure Draft Prepayments of a Minimum Funding Requirement - Proposed amendments to IFRIC 14. We have considered the ED, as well as the accompanying draft Basis for Conclusions. We support the Board in its proposals to amend IFRIC 14 IAS 19 - The Limit on a Defined Benefit Asset, Minimum Funding Requirements and their Interaction (IFRIC 14).

•   Discussion Paper: Leases - Preliminary Views (July 16, 2009) (146 KB)

  Grant Thornton International Ltd and its US member firm, Grant Thornton LLP, are pleased to comment on the International Accounting Standards Board's (the IASB) and the Financial Accounting Standards Board's (the FASB) joint Discussion Paper: Leases - Preliminary Views (the Discussion Paper). We summarise our main comments in the following letter. Our detailed comments and responses to the Invitation to Comment questions are included in the Appendix.

•   Exposure Draft ED/2009/2 Income Tax (July 10, 2009) (148 KB)

  Grant Thornton LLP is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/2 Income Tax (the ED). In summary, we do not support the introduction of an IFRS along the lines proposed in the ED. We are not convinced that the proposals, taken as a whole, represent an overall improvement on IAS 12. We also believe that the proposals will fail to achieve the goals set by the Board.

•   Exposure Draft ED/2009/03 Derecognition - Proposed Amendments to IAS 39 and IFRS 7 (July 10, 2009) (143 KB)

  Grant Thornton LLP supports the Board's decision to review the derecognition requirements of IAS 39 Financial Instruments: Recognition and Measurement (IAS 39). We share the Board's concern that these requirements are unduly complex and give rise to frequent application issues. Further, we believe that IAS 39's 'continued recognition to the extent of continuing involvement' outcome can lead to double-counting and may not generally provide useful information.

•   Discussion Paper: Preliminary Views on Revenue Recognition in Contracts with Customers (June 18, 2009) (62 KB)

  Grant Thornton LLP supports the Boards' reasons for undertaking a comprehensive review of revenue recognition principles. The case for change has been well articulated by the Boards and we welcome the development of a converged solution.

•   Discussion Paper: Preliminary Views on Financial Statement Presentation (April 9, 2009) (222 KB)

  Grant Thornton LLP supports the project and commends the Boards for developing joint proposals. In particular, we support improving the alignment of items within and across primary statements. We also support the introduction of a reconciliation schedule to provide better information on the linkage between primary statements. However, we have a number of significant concerns on some aspects of the proposals that we consider will need significant reworking in order to achieve improvements in practice.

•   Review of the Constitution: Identifying Issues for Part 2 of the Review (March 25, 2009) (171 KB)

  Grant Thornton International is pleased to comment on the IASC Foundation's Consultation Document Review of the Constitution: Identifying Issues for Part 2 of the Review (Part 2 of the Constitution Review). We welcome the opportunity to comment at this relatively early stage of Part 2 of the Constitution Review. In the following paragraphs we offer some broad themes that we believe should be considered by the IASC Foundation (the Foundation) in developing more detailed proposals. Our responses to the specific questions raised by the Trustees are set out in the Appendix to this letter.

•   Exposure Draft 10 Consolidated Financial Statements (March 18, 2009) (169 KB)

  Grant Thornton International welcomes the Board's efforts to unify IAS 27 and SIC-12 based on a clear principle. This should eliminate tension between the two models and uncertainty as to which model applies to some entities. We also support ED10's broad approach - in particular its clear focus on control as the basis for consolidation of another entity. However, we do have some significant concerns which are explained.

•   Exposure Draft Relationships with the State (March 9, 2009) (105 KB)

  Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft of Relationships with the State (the ED). We have considered the ED, as well as the accompanying draft Basis for Conclusions. Our responses to the questions in the ED's Invitation to Comment are set out in the attached.

•   Exposure Draft Post-implementation Revisions to IFRIC Interpretations (proposed amendments to IFRIC 9 and IFRIC 16) (February 26, 2009) (126 KB)

  Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft Post-implementation Revisions to IFRIC Interpretations (the ED). We have considered the ED, as well as the accompanying draft Basis for Conclusions. Our responses to the questions in the ED's Invitation to Comment are set in this letter.

•   Proposed Amendments to IFRIC 9 and IAS 39 (January 20, 2009) (106 KB)

  Grant Thornton International supports the Board's decision to clarify the interaction between IFRIC 9 and the recent reclassification amendments to IAS 39. We also agree that financial assets reclassified out of the fair value through profit or loss category should not escape IAS 39's requirements on embedded derivatives.

•   Exposure Draft Additional Exemptions for First-time Adopters - Proposed Amendments to IFRS 1 (January 16, 2009) (107 KB)

  Grant Thornton International supports the proposals of the International Accounting Standards Board's Exposure Draft Additional Exemptions for First-time Adopters - Proposed Amendments to IFRS 1 (the ED).

•   Proposed Amendments to IFRS 5 (January 16, 2009) (109 KB)

  Grant Thornton International is generally supportive of the specific proposals. However, we believe that the proposed definition of a discontinued operation may need to be refined to be more consistent with its underlying rationale. We also have a concern that the proposed disclosures relating to disposals of other components may capture too many transactions.

•   Exposure Draft Investments in Debt Instruments - Proposed Amendments to IFRS 7 (January 14, 2009) (99 KB)

  Grant Thornton International has considered the Exposure Draft along with the accompanying draft Basis for Conclusions. In summary, we believe there is a good case for requiring disclosures that enable users to better understand the nature of impairment losses recognised on available for sale debt assets. We are not convinced that this is an urgent matter. However, should the Board decide that fast track amendments are necessary we would prefer a more limited disclosure requirement that focuses more narrowly on this specific matter.

•   Exposure Draft Proposed Amendments to IFRS 7 Financial Instruments (December 15, 2008) (45 KB)

  The firm supports the direction of the proposals. We have a concern over the impact of the proposed effective date when considered in conjunction with retrospective application of the amendments. We have also identified a small number of areas where we believe the disclosure burden could be eased somewhat without detracting from the usefulness of the information provided. In addition, we have suggestions for expressing certain of the proposed amendments more clearly.

•   IFAC's Support for a Single Set of Auditing Standards: Implications for Audits of Small and Medium-Sized Entities (November 11, 2008) (25 KB)

  Grant Thornton International Ltd has long supported the ultimate goal of one set of recognized global auditing standards, and along with the International Federation of Accountants, strongly support the work of the International Auditing and Assurance Standards Board in achieving its objective of establishing International Standards on Auditing (ISAs) that are applicable to audits of all entities, regardless of their size or complexity.

•   Exposure Draft Proposed Improvements to Financial Reporting Standards (November 6, 2008) (140 KB)

  The firm agrees with the substance of most of the proposed amendments. We also consider that the proposed amendments are (with one exception) appropriate matters to be addressed in the annual improvements process and welcome the reduction in the number of proposals compared to the 2007 Exposure Draft.

•   An improved Conceptual Framework for Financial Reporting: The Objective of Financial Reporting and Qualitative Characteristics and Constraints of Decision-Useful Financial Reporting (September 22, 2008) (131 KB)

  Grant Thornton International and Grant Thornton LLP believe the Exposure Draft is a significant improvement over the Preliminary Views document.

•   Conceptual Framework for Financial Reporting: The Reporting Entity (September 22, 2008) (131 KB)

  Grant Thornton International and Grant Thornton LLP support the Boards' efforts to update and enhance the conceptual framework to provide a foundation for developing principles-based on converged standards.

•   Review of the Constitution: Public Accountability and the Composition of the IASB - Proposals for Change (September 16, 2008) (131 KB)

  Grant Thornton International supports the review of the IASC Foundation's Consultation Document and congratulates the Trustees for taking this step.

•   Discussion Paper Reducing Complexity in Reporting Financial Instruments (September 16, 2008) (162 KB)

  Grant Thornton International responded to the Discussion Paper Reducing Complexity in Reporting Financial Instruments. Grant Thornton International supports reducing complexity and is concerned with a full fair value approach.

•   Discussion Paper Preliminary Views on Amendments to IAS 19 Employee Benefits (September 16, 2008) (151 KB)

  Grant Thornton International responded to IASB's Discussion Paper Preliminary Views on Amendments to IAS 19 Employee Benefits. Grant Thornton International supports the elminiation of the 'corridor'.

•   Discussion Paper Financial Instruments with Characteristics of Equity (August 18, 2008) (44 KB)

  Grant Thornton LLP responded to the Financial Accounting Standards Board's Preliminary Views document on 30 May 2008. Grant Thornton International Ltd. supports the views and comments in that letter. The purpose of this additional letter is to respond to the further matters raised in the IASB Paper's Invitation to Comment.

•   IFRIC Draft Interpretation D24 Customer Contributions (April 7, 2008) (42 KB)

  Grant Thornton International Ltd  agrees that accounting for customer contributions is an area of diversity in practice and supports the IFRIC's decision to develop guidance.

•   IFRIC Draft Interpretation D23 Distributions of Non-cash Assets to Owners (April 4, 2008) (42 KB)

  Grant Thornton International Ltd agrees that accounting for distributions of non-cash assets to owners is an area of diversity in practice and therefore supports the IFRIC's decision to develop guidance.

•   Grant Thornton International Ltd comments to IASB re: Exposure Draft Proposed Amendments to IFRS 1 (February 25, 2008) (34 KB)

  Comments regarding Exposure Draft Proposed Amendments to IFRS 1 First-time Adoption of International Financial Reporting Standards and IAS 27 Consolidated and Separate Financial Statements:  Cost of an Investment in a Subsidiary, Jointly Controlled Entity or Asociate.

•   Grant Thornton International Ltd comments to IASB on Share-based Payment (February 25, 2008) (32 KB)

  Comments regarding Exposure Draft Proposed Amendments to IFRS 2 Share-based Payment and IFRIC 11 IFRS 2 - Group and Treasury Share Transactions: Group Cash-settled Share-Based Payment Transactions.

•   IASB's Exposure Draft ED 9 Joint Arrangements (January 7, 2008) (23 KB)

  Grant Thornton International delineates certain reservations regarding the IASB's Exposure Draft ED 9 Joint Arrangements.

•   IASB's Exposure Draft of Proposed Amendments to IAS 39 Financial Instruments: Recognition and Measurement Exposures Qualifying for Hedge Accounting (January 7, 2008) (31 KB)

  Grant Thornton International supports most of the proposals in the Exposure Draft.

•   IASB's first annual Exposure Draft of Proposed Improvements to Financial Reporting Standards (January 7, 2008) (42 KB)

  Grant Thornton International supports the Board's objective of providing a streamlined approach to dealing with miscellaneous necessary but minor amendments to standards.

•   Comments to SEC regarding Concept Release on Allowing U.S. Issuers To Prepare Financial Statements in Accordance With IFRS (November 13, 2007) (67 KB)

  Grant Thornton LLP's comments include support of a voluntary program that allows U.S. issuers to prepare financial statements in accordance with IFRS as published by the IASB.

•   Exposure Draft of a Proposed IFRS for Small and Medium-sized Entities (October 25, 2007) (312 KB)

  Comment letter supporting the IASB's project to produce a high quality, more practicable alternative to full IFRS in response to demand from constituents to take account of the needs of small and medium-sized entities and emerging economies.

•   Enlarging IFRIC (July 20, 2007) (13KB)

  Grant Thornton International supports International Accounting Standards Committee Foundation proposals to enlarge the International Financial Reporting Interpretations Committee (IFRIC).

•   State-controlled entities and the definition of a related party (May 24, 2007) (115KB)

  Grant Thornton International comments on the International Accounting Standard Board's Exposure Draft of Proposed Amendments to IAS 24 State-controlled Entities and the Definition of a Related Party.

•   IASB Discussion Paper on fair value measurements (May 3, 2007) (82KB)

  Grant Thornton International provides comments to the International Accounting Standards Board on its Discussion Paper, Fair Value Measurements.

•   Comments to IASB from Grant Thornton International on cost of investment in a subsidiary (April 23, 2007) (32KB)

  Grant Thornton International comments on the International Accounting Standards Board (IASB) Exposure Draft - Amendments to IFRS 1 First-time Adoption of International Financial Reporting Standards: Cost of an Investment in a Subsidiary ("the ED").

•   March 31, 2006--Comments to the International Accounting Standards Board (65KB)

  Comments from Grant Thornton International on the IASB's Discussion Paper, "Management Commentary."

•   March 20, 2006--Comments to the International Accounting Standards Board (39KB)

  Grant Thornton International comments on the International Financial Reporting Interpretations Committee’s (IFRIC) Draft Interpretation D18 Interim Financial Reporting and Impairment.

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