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Comment Letter - FASB proposed guidance for common control arrangements


In our comment letter, we express support for the FASB’s efforts to address feedback about ASC 842, Leases, in its post-implementation review process. We suggest clarifications to improve operability of the proposal for preparers and recommend additional required disclosures for a private company that elects to use the proposed practical expedient to identify, classify and account for leases under common control based on written terms and conditions. We also recommend certain clarifications that may enhance the operability of the proposed accounting for leasehold improvements in all common control arrangements.

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