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US GAAP versus IFRS - Leases - EY - United States

US GAAP versus IFRS

Leases

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Similarities

The overall accounting for leases under US GAAP and IFRS (ASC 840, Leases and IAS 17, Leases, respectively) is similar, although US GAAP has more specific application guidance than IFRS. Both focus on classifying leases as either capital (IAS 17 uses the term "finance") or operating, and both separately discuss lessee and lessor accounting.

Lessee accounting (excluding real estate)

Both US GAAP and IFRS require the party that bears substantially all the risks and rewards of ownership of the leased property to recognize a lease asset and corresponding obligation, and provide criteria (ASC 840) or indicators (IAS 17) to determine whether a lease is capital or operating. The criteria or indicators of a capital lease are similar in that both standards include the transfer of ownership to the lessee at the end of the lease term and a purchase option that, at inception, is reasonably expected to be exercised.

ASC 840 requires capital lease treatment if the lease term is equal to or greater than 75% of the asset's economic life, while IAS 17 requires such treatment when the lease term is a "major part" of the asset's economic life. ASC 840 specifies capital lease treatment if the present value of the minimum lease payments exceeds 90% of the asset's fair value, while IAS 17 uses the term "substantially all" of the fair value.

In practice, while ASC 840 specifies bright lines in certain instances, IAS 17's general principles are interpreted similarly to the bright-line tests. As a result, lease classification is often the same under ASC 840 and IAS 17.

Under both US GAAP and IFRS, a lessee would record a capital (finance) lease by recognizing an asset and a liability, measured at the lower of the present value of the minimum lease payments or fair value of the asset. A lessee would record an operating lease by recognizing expense on a straight-line basis over the lease term. Any incentives under an operating lease are amortized on a straight-line basis over the term of the lease.

Lessor accounting (excluding real estate)

Lessor accounting under ASC 840 and IAS 17 is similar and uses the above tests to determine whether a lease is a sales-type/direct financing lease (referred to as a finance lease under IAS 17) or an operating lease. ASC 840 specifies two additional criteria (i.e., collection of lease payments is reasonably expected and no important uncertainties surround the amount of unreimbursable costs to be incurred by the lessor) for a lessor to qualify for sales-type/direct financing lease accounting that IAS 17 does not.

Although not specified in IAS 17, it is reasonable to expect that if these conditions exist, the same conclusion may be reached under both standards. If a lease is a sales-type/direct financing (finance) lease, the leased asset is replaced with a lease receivable. If a lease is classified as operating, rental income is recognized on a straight-line basis over the lease term, and the leased asset is depreciated by the lessor over its useful life.

Significant differences


 US GAAPIFRS
Lease of real estateA lease of land and buildings that transfers ownership to the lessee or contains a bargain purchase option would be classified as a capital lease by the lessee, regardless of the relative value of the land.

If the fair value of the land at inception represents less than 25% of the total fair value of the lease, the lessee accounts for the land and building components as a single unit for purposes of evaluating the 75% and 90% tests noted above.

Otherwise, the lessee must consider the land and building components separately for purposes of evaluating other lease classification criteria. (Note: Only the building is subject to the 75% and 90% tests in this case.)
The land and building elements of the lease are considered separately when evaluating all indicators unless the amount that would initially be recognized for the land element is immaterial, in which case they would be treated as a single unit for purposes of lease classification. There is no 25% test to determine whether to consider the land and building separately when evaluating certain indicators.
Recognition of a gain or loss on a sale and leaseback when the leaseback is an operating leasebackIf the seller does not relinquish more than a minor part of the right to use the asset, gain or loss is generally deferred and amortized over the lease term. If the seller relinquishes more than a minor part of the use of the asset, then part or all of a gain may be recognized depending on the amount relinquished. (Note: Does not apply if real estate is involved, as the specialized rules are very restrictive with respect to the seller's continuing involvement, and they may not allow for recognition of the sale.)Gain or loss is recognized immediately, subject to adjustment if the sales price differs from fair value.
Recognition of gain or loss on a sale-leaseback when the leaseback is a capital leasebackGenerally, same as above for operating leaseback in which the seller does not relinquish more than a minor part of the right to use the asset.Gain or loss deferred and amortized over the lease term.

Other differences include: (i) the treatment of a leveraged lease by a lessor under ASC 840 (IAS 17 does not have such classification), (ii) real estate sale-leasebacks, (iii) real estate sales-type leases, (iv) leases of land and (v) the rate used to discount minimum lease payments to the present value for purposes of determining lease classification and subsequent recognition of a capital lease, including in the event of a renewal.

Convergence

As part of their convergence efforts, the Boards are redeliberating their joint exposure draft on lease accounting that would create a common standard for lease accounting and require that assets and liabilities arising under most lease contracts be recognized on the balance sheet. The Boards plan to re-expose their proposals due to the significant changes made to the model during redeliberations.



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