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Comment Letter - FASB proposal on targeted improvements to the accounting for internal-use software


Overview

In our comment letter, we support the FASB’s efforts to address stakeholder feedback to modernize the accounting for internal-use software costs, better align the internal-use software guidance with that for external-use software and enhance the transparency of an entity’s cash flows related to software costs. While we support the FASB’s objective overall, we recommend it reconsider certain aspects of the proposal to improve operability of the proposed guidance.

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