International Accounting, 6/eFrederick D.S. ChoiGary K. MeekChapter 4: Comparative Accounting: The Americas and Asia1Learning ObjectiveslUnderstand how financial reporting is regulated and enforced in five countries of the Americas and Asia: the U.S., Mexico, Japan, China, and India.lDescribe the key similarities and differences among the accounting systems of these five countries.lDescribe the auditor-oversight mechanisms in these five countries.lExplain the difference between principles-based and rules-based accounting standards.23United StateslOverviewlFinancial Accounting Standards Board (FASB)lPrivate-sector organization that determines accounting standardslThe Securities and Exchange Commission (SEC) a governmental agency underpins FASBs authoritylPublic Company Accounting Oversight Board (PCAOB)lPrivate organization overseen by the SEClRegulates audits and auditors of public companieslIn 2002, took over the responsibility for setting auditing standards from the American Institute of Certified Public Accountants (AICPA)lFinancial statements “present fairly”lCompliance with GAAP is the test for fair presentation4United States (contin)lAccounting regulation and enforcementlSecurities and Exchange CommissionlHas jurisdiction over listed companieslRelies on private sector (FASB) to set accounting standardslPressures FASB on the direction of accounting standardslFinancial Accounting Standards BoardlConceptual Framework is a significant feature of accounting standard settinglStandard setting in the U.S. is both political and technicallGenerally accepted accounting principles (GAAP) are voluminous and detailedlCommitted to converging U.S. GAAP with IFRSlSarbanes-Oxley Act (2002)lExpanded requirements on corporate governance, disclosure and reporting, and the regulation of the audit professionlEstablished PCAOBSets standards for auditorsOversees and inspects audit firmsSanctions auditors for defective worklCEO and CFO must certify financial statementslManagement must assess internal controlslAuditors express an opinion on internal controls5United States (contin)lUnusual features of U.S. financial reportinglNo federal law for preparing financial statements or having them audited, except for listed companieslLIFOlRules-based GAAP versus principles-based GAAPlRules-basedMore specific requirementsMore detailed implementation guidanceMay result in more comparabilityMay foster “check-the-box” mentalitylPrinciples-basedSets forth broad objectives and fundamentalsRequires professional judgment for implementationMore flexibleMay result in more divergence in practice6MexicolOverviewlAccounting is oriented toward fair presentation despite code law legal systemlGeneral price-level accounting (inflation-adjusted financial statements) are a fundamental featurelAccounting profession is well-developed and influential in setting accounting and auditing standardslAccounting regulation and enforcementlCouncil for Research and Development of Financial Information Standards (CINIF)lIndependent public/private-sector partnership patterned after FASB and IASBlDetermines Mexican GAAPlAim align Mexican GAAP with IFRSlMexican Institute of Public AccountinglIssues auditing standards through its Auditing Standards and Procedures CommissionlUnusual features of Mexican financial reportinglFinancial statements are adjusted for inflation7JapanlOverviewlStrong bureaucratic control over business, including accountinglStructural reforms under waylKeiretsu business model being transformedlAccounting “big bang” to improve transparency8JapanlAccounting regulation and enforcementlTriangular legal systemlCompany LawAdministered by Ministry of JusticeCreditor and shareholder protection the fundamental principlelSecurities and Exchange LawFor publicly owned companiesProviding information for investment decision-making the main objectivelCorporate Income Tax LawExpenses must be booked to be claimed for tax purposeslAccounting Standards Board of JapanlPrivate-sector organizationlResponsible for developing accounting standardslModeled after FASB and IASBlConvergence with IFRS a major goallTook over from the Business Accounting Council (a government agency) in 2001lJapanese Institute of Certified Public AccountantslProvides guidance on conduct of auditlBusiness Accounting Council lResponsible for auditing standardslCertified Public Accountant and Auditing Oversight BoardlGovernment agencylMonitors and oversees the auditing profession9Japan (contin)lUnusual features of Japanese financial reportinglForecasts of cash flows, capital investments, and production in statutory filings10ChinalOverviewlEmbracing IFRS as part of structural market reformslMinistry of Finance responsible for all aspects of accounting and auditing 11China (contin)lAccounting regulation and enforcementlChinese Accounting Standards CommitteelUnder the Ministry of FinancelResponsible for developing accounting standardslChinese Institute of Certified Public AccountantslUnder the Ministry of FinancelResponsible for developing auditing standards and code of professional ethicslChina Securities Regulatory CommissionlUnder Ministry of FinancelRegulates Chinas two stock exchangeslAccounting Standards for Business Enterprises (ASBE)lComprehensive framework for accounting and financial reportinglIncludes detailed implementation guidance on accounting issueslLargely in line with IFRSlFirst introduced in 1992 by Ministry of Finance and revised several times sincelUnusual features of Chinese financial reportinglStartling changes since original ASBE in 199212IndialOverviewlBritish influence on accounting and auditing For example:lTrue and fair viewlIndependent accounting profession13India (contin)lAccounting regulation and enforcementlCompanies ActlBroad framework for accounting and auditinglInstitute of Chartered Accountants of IndialSupervised by Ministry of Company Affairs, a government agencylRegulates profession of chartered accountancylResponsible for developing both accounting and auditing standardsAccounting Standards BoardIssues Indian Accounting StandardsAuditing and Assurance Standards BoardIssues Auditing and Assurance StandardslSecurities and Exchange Board of IndialAgency of the Ministry of FinancelOversees stock marketslUnusual features of Indian financial reportinglSome practices are “behind” developed world, but moving to adopt IFRS1415Other Chapter Exhibits16Other Chapter Exhibits (contin)17