No. 2015-75 28 October 2015 To the Point FASB — proposed guidance FASB may require additional income tax disclosures The Board’s tentative decisions would not change the accounting for income taxes. What you need to know • The FASB tentatively decided to require additional income tax disclosures of changes in tax laws, taxes paid, valuation allowances, tax rate reconciliations, deferred taxes and tax carryforwards. • The FASB made these decisions as part of its broader disclosure framework project. • Before amending the income tax disclosure guidance, the FASB would need to issue a formal proposal seeking public comment. The FASB plans to perform outreach on its tentative decisions on income tax disclosures before issuing a proposal. Overview The Financial Accounting Standards Board (FASB or Board) tentatively decided to require additional income tax disclosures of changes in tax laws, taxes paid, valuation allowances, tax rate reconciliations, deferred taxes and tax carryforwards. The FASB made these decisions as part of its broader disclosure framework project. The disclosure framework project is aimed at improving the effectiveness of disclosures in the notes to the financial statements by changing the requirements to clearly communicate the most important information. As part of the project, the Board is reviewing disclosure requirements for income taxes, inventory, fair value measurement, defined benefit plans and interim reporting. The Board made other tentative decisions on income tax disclosures related to foreign earnings and indefinite reinvestment assertions 1 and unrecognized tax benefits 2 at meetings earlier this EY AccountingLink | ey.com/us/accountinglink year. If the FASB decides to pursue changes to today’s income tax disclosure requirements, it would have to issue a formal proposal and seek public comment on it. The FASB plans to perform outreach on its tentative decisions on income tax disclosures before issuing a proposal. Key decisions Changes in tax laws Under today’s guidance, entities are required to disclose the significant components of income tax expense attributable to continuing operations, including adjustments to deferred taxes for enacted changes in tax laws or rates. 3 The FASB tentatively decided to also require entities to disclose information about an enacted change in tax law if it is probable that the change will affect the entity in a future period. Taxes paid Today, entities must present or disclose the amount of income taxes paid during the period. The FASB tentatively decided to require all entities to disclose income taxes paid disaggregated by domestic income taxes paid and foreign income taxes paid. Valuation allowances Entities are currently required to disclose the total valuation allowance recognized for deferred tax assets and the net change in the total valuation allowance for the year. 4 The Board tentatively decided to also require that entities provide an explanation of the nature and amounts of valuation allowances recorded and released during the reporting period. Tax rate reconciliations Public entities are currently required to reconcile the income tax expense (or benefit) from continuing operations to the amount that would result from applying the domestic federal statutory rate to pretax income (loss) from continuing operations,5 using percentages or dollar amounts. The estimated amount and the nature of each significant reconciling item should be disclosed. Nonpublic entities are required to disclose the nature of significant reconciling items but may omit a numerical reconciliation. 6 All entities are also required to disclose the nature and effect of any significant matters affecting comparability of information for all periods presented, if this is not evident from the other disclosures. 7 The FASB tentatively decided to require nonpublic entities to disclose rate reconciliations consistent with the requirement for public entities. The FASB also decided to require all entities to disclose individual reconciling items that amount to more than 5% of the amount computed by multiplying pretax income (loss) by the applicable federal statutory income tax rate. This change would better align the FASB’s guidance with the Securities and Exchange Commission’s guidance.8 The FASB also decided to require a qualitative description of items that have caused a significant change in the rate year over year. Deferred taxes Currently, entities are required to separately disclose the totals of deferred tax liabilities, deferred tax assets and valuation allowances recognized for deferred tax assets. 9 The FASB tentatively decided to require entities to disclose where these amounts are recorded on the balance sheet if deferred taxes are not presented as a separate line item. 2 | To the Point FASB may require additional income tax disclosures 28 October 2015 EY AccountingLink | ey.com/us/accountinglink Tax carryforwards Under current guidance, entities are required to disclose the amounts and expiration dates of operating losses and tax credit carryforwards for tax purposes.10 The Board tentatively decided to amend the current guidance to require disclosure of: • The amounts and expiration dates of the carryforwards recorded on the tax return (i.e., not tax effected) • The amounts and expiration dates of the carryforwards that give rise to a deferred tax asset (i.e., tax effected) • The total amount of unrecognized tax benefits that offset the carryforwards What’s next The FASB plans to perform outreach on its tentative decisions on income tax disclosures before issuing a proposal. As a result, the Board could decide to revisit these decisions. The Board will discuss a proposed effective date and transition provisions after performing its outreach. Endnotes: 1 2 3 4 5 6 7 8 9 10 EY | Assurance | Tax | Transactions | Advisory © 2015 Ernst & Young LLP. All Rights Reserved. SCORE No. BB3072 ey.com/us/accountinglink See our To the Point publication, FASB may add income tax disclosures related to foreign earnings. See our To the Point publication, FASB may change income tax disclosure requirements related to unrecognized tax benefits. Accounting Standards Codification (ASC) 740-10-50-9. ASC 740-10-50-2. ASC 740-10-50-12. ASC 740-10-50-13. ASC 740-10-50-14. Regulation S-X, Rule 4-08(h)(2). ASC 740-10-50-2. ASC 740-10-50-3. About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com. Ernst & Young LLP is a client-serving member firm of Ernst & Young Global Limited operating in the US. This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice. 3 | To the Point FASB may require additional income tax disclosures 28 October 2015