15.3 Lessor Disclosure Requirements

ASC 842-30

50-1 The objective of the disclosure requirements is to enable users of financial statements to assess the amount, timing, and uncertainty of cash flows arising from leases. To achieve that objective, a lessor shall disclose qualitative and quantitative information about all of the following:

Its leases (as described in paragraphs 842-30-50-3(a), 842-30-50-4, and 842-30-50-7)
The significant judgments made in applying the requirements in this Topic to those leases (as described in paragraph 842-30-50-3(b))
The amounts recognized in the financial statements relating to those leases (as described in paragraphs 842-30-50-5 through 50-6 and 842-30-50-8 through 50-13).

50-2 A lessor shall consider the level of detail necessary to satisfy the disclosure objective and how much emphasis to place on each of the various requirements. A lessor shall aggregate or disaggregate disclosures so that useful information is not obscured by including a large amount of insignificant detail or by aggregating items that have different characteristics.

50-8 In addition to the disclosures required by paragraphs 842-30-50-3 through 50-7, a lessor also shall provide the disclosures in paragraphs 842-30-50-9 through 50-10 for sales-type leases and direct financing leases.

50-11 In addition to the disclosures required by paragraphs 842-30-50-3 through 50-7, a lessor also shall provide the disclosures in paragraphs 842-30-50-12 through 50-13 for operating leases.

The disclosure objective for lessors is the same as that for lessees (i.e., “to enable users of financial statements to assess the amount, timing, and uncertainty of cash flows arising from leases”). However, a lessor should consider the different, lessor-related information that a user of its financial statements may be concerned about. Paragraph BC16 of ASU 2016-02 indicates that part of the reason the FASB increased the lessor disclosure requirements was because disclosures under ASC 840 were insufficient:

Some users of financial statements also criticized previous GAAP applicable to lessors because that guidance did not provide adequate information about a lessor’s exposure to credit risk (arising from a lease) and exposure to asset risk (arising from the lessor’s retained interest in the underlying asset), particularly for those leases of assets that were previously classified as operating leases.

Illustrative Example — Disclosure Disaggregation

The following are examples of ways a lessor may choose to disaggregate its lessor disclosures:

Another reason ASC 842 requires more disclosures for lessors is that the Board views a lessor’s activities as similar to other revenue-generating activities, and the lack of disclosure regarding revenue was a key issue that the Board addressed in its project on revenue from contracts with customers.

The lessor disclosure requirements are further subdivided into the following topics:

Information about the nature of an entity’s leases (Section 15.3.1).
- General description of leases (Section 15.3.1.1).
- Basis and terms and conditions on which variable lease payments are determined (Section 15.3.1.2).
- Terms and conditions of options to extend or terminate leases (Section 15.3.1.3).
- Existence of terms and conditions for a lessee to purchase a leased asset (Section 15.3.1.4).
Significant assumptions and judgments (Section 15.3.2).
- Whether a contract contains a lease (Section 15.3.2.1).
- Allocation of consideration in a contract (Section 15.3.2.2).
- Amount lessor expects to derive from underlying asset after the end of the lease term (Section 15.3.2.3).
- Practical-expedient disclosure related to not separating lease and nonlease components (Section 15.3.2.4).
Lease transactions with related parties (Section 15.3.3).
Residual assets and risk management (Section 15.3.4).
Amounts recognized in the financial statements (Section 15.3.5).
- Sales-type leases and direct financing leases (Section 15.3.5.1).
  - Tabular disclosures (Section 15.3.5.1.1).
  - Components of net investments in leases (Section 15.3.5.1.2).
  - Significant changes in the balance of unguaranteed residual assets and deferred selling profit (Section 15.3.5.1.3).
  - Maturity analysis of lease receivables (Section 15.3.5.1.4).
- Operating leases (Section 15.3.5.2).
  - Tabular disclosures (Section 15.3.5.2.1).
  - Maturity analysis of lease payments (Section 15.3.5.2.2).
  - Separate ASC 360 disclosures (Section 15.3.5.2.3).
- Variable lease income (Section 15.3.5.3).
Practical-expedient disclosure related to sales taxes and other similar taxes collected from lessees (Section 15.3.6).

15.3.1 Information About the Nature of an Entity’s Leases

ASC 842-30

50-3 A lessor shall disclose both of the following:

Information about the nature of its leases, including:
1. A general description of those leases
2. The basis and terms and conditions on which variable lease payments are determined
3. The existence and terms and conditions of options to extend or terminate the lease
4. The existence and terms and conditions of options for a lessee to purchase the underlying asset. . . .

A lessor should disclose information about its leases in a manner consistent with the disclosure objective described above. Generally, disclosures provided under this requirement are more qualitative.

15.3.1.1 General Description of Leases

ASC 842-30

50-3 A lessor shall disclose both of the following:

Information about the nature of its leases, including:
1. A general description of those leases . . . .

The considerations related to a lessor’s disclosure of a general description of its leases are similar to those for lessees. See Section 15.2.1.1 for more information.

Illustrative Example — General Description of an Entity’s Leases

15.3.1.2 Basis and Terms and Conditions on Which Variable Lease Payments Are Determined

ASC 842-30

50-3 A lessor shall disclose both of the following:

Information about the nature of its leases, including: . . .
2. The basis and terms and conditions on which variable lease payments are determined . . . .

As discussed in Section 6.3, only some variable lease payments (those based on an index or rate) are included in the initial and subsequent measurement of any (1) recognized net investment in the lease for sales-type or direct financing leases or (2) lease receivables for operating leases. Because variable lease payments are treated in different ways, the determination of what type of variability exists in a lease contract and whether that variability is included or excluded from amounts recognized on the balance sheet is critical to understanding lease income and achieving the disclosure objective (i.e., information about the timing and uncertainty of the entity’s cash flows). Therefore, the terms and conditions related to variability provide the user with information about amounts that are not recorded on the balance sheet because variable lease payments not based on an index or rate are not included in recorded balance sheet amounts and could be considered more volatile forms of revenue and potential future cash inflows.

Therefore, although it is not expressly required to do so, it may be helpful for an entity to describe the sources of the variability in two separate groups: (1) the amounts included in the net investment in the lease and (2) the variability that is excluded. In addition, an entity must explain the types of variability within its contracts, and that explanation must include a discussion of key terms and conditions. For example, an entity may receive variable lease payments because a lessee’s rental payment is determined on the basis of a percentage of its store’s sales. Because of its volatility, users view this variability differently from how they view a fixed rental payment; the more transparent the source of that volatility, the better a user can understand the nature, timing, and uncertainty of the entity’s future cash flows. Sometimes, however, the variability in future lease payments may be more complex, in which case a lessor may need to provide additional information.

Illustrative Example — Basis and Terms and Conditions on Which Variable Lease Payments Are Determined

Variable lease payments that are based on an index or rate:

15.3.1.3 Terms and Conditions of Options to Extend or Terminate Leases

ASC 842-30

50-3 A lessor shall disclose both of the following:

Information about the nature of its leases, including: . . .
3. The existence and terms and conditions of options to extend or terminate the lease . . . .

Disclosures about terms and conditions related to options to extend or terminate leases should allow a user to assess the rights of the entity’s customers in the contracts. Such information may be helpful for users who want to understand situations in which lessors have contractually agreed to lease payments that may not be at market terms in the future (i.e., fixed-price renewal options on real estate).

Illustrative Example — Terms and Conditions of Options to Extend or Terminate Leases

15.3.1.4 Existence of Terms and Conditions for a Lessee to Purchase a Leased Asset

ASC 842-30

50-3 A lessor shall disclose both of the following:

Information about the nature of its leases, including: . . .
4. The existence and terms and conditions of options for a lessee to purchase the underlying asset. . . .

Regardless of whether it is reasonably certain that a lessee will exercise a right to purchase an underlying asset, a lessor should disclose the existence of such terms and conditions. Such disclosure allows a user to understand when there may be an effective cap on the cash flows realizable in the contract (e.g., if the purchase option is a fixed-price purchase option).

15.3.2 Significant Assumptions and Judgments

ASC 842-30

50-3 A lessor shall disclose both of the following: . . .

b. Information about significant assumptions and judgments made in applying the requirements of this Topic, which may include the following:

1. The determination of whether a contract contains a lease (as described in paragraphs 842-10-15-2 through 15-27)

2. The allocation of the consideration in a contract between lease and nonlease components (as described in paragraphs 842-10-15-28 through 15-32), unless a lessor elects the practical expedient in paragraph 842-10-15-42A and all nonlease components in the contract qualify for that practical expedient

3. The determination of the amount the lessor expects to derive from the underlying asset following the end of the lease term.

50-3A An entity that elects the practical expedient in paragraph 842-10-15-42A on not separating nonlease components from associated lease components (including an entity that accounts for the combined component entirely in Topic 606 on revenue from contracts with customers) shall disclose the following, by class of underlying asset:

Its accounting policy election and the class or classes of underlying assets for which it has elected to apply the practical expedient
The nature of:
1. The lease components and nonlease components combined as a result of applying the practical expedient
2. The nonlease components, if any, that are accounted for separately from the combined component because they do not qualify for the practical expedient
The Topic the entity applies to the combined component (this Topic or Topic 606).

The considerations related to a lessor’s disclosures about significant assumptions and judgments are similar to those for lessees. For more information, see Section 15.2.3.

15.3.2.1 Whether a Contract Contains a Lease

ASC 842-30

50-3 A lessor shall disclose both of the following: . . .

b. Information about significant assumptions and judgments made in applying the requirements of this Topic, which may include the following:

1. The determination of whether a contract contains a lease (as described in paragraphs 842-10-15-2 through 15-27) . . . .

The lessor’s considerations related to disclosures about significant judgments used to determine whether a contract contains a lease are similar to those for lessees. For more information, see Section 15.2.3.1.

Illustrative Example — Whether a Contract Contains a Lease

15.3.2.2 Allocation of Consideration in a Contract

ASC 842-30

50-3 A lessor shall disclose both of the following: . . .

b. Information about significant assumptions and judgments made in applying the requirements of this Topic, which may include the following: . . .

The lessor’s considerations related to disclosures about significant judgments used to determine the allocation of consideration in a contract are similar to those for lessees. For more information, see Section 15.2.3.2.

Illustrative Example — Allocation of Consideration in a Contract

Note that in July 2018, the FASB issued ASU 2018-11, which contains a practical expedient under which lessors can elect, by class of underlying asset, not to separate lease and nonlease components, provided that the associated nonlease component(s) otherwise would be accounted for under the revenue guidance in ASC 606 and both of the following conditions are met:

Criterion A — The timing and pattern of transfer for the lease component are the same as those for the nonlease components associated with that lease component.
Criterion B — The lease component, if accounted for separately, would be classified as an operating lease.

The ASU also clarifies that the presence of a nonlease component that is ineligible for the practical expedient does not preclude a lessor from electing the expedient for the lease component and nonlease component(s) that meet the criteria. Rather, the lessor would account for the nonlease components that do not qualify for the practical expedient separately from the combined lease and nonlease components that do qualify.

See Section 4.3.3.2 for further details about the practical expedient related to a lessor’s separation of lease and nonlease components. In addition, see Section 15.3.2.4 for the disclosure requirements, and Section 16.4.6 for the transition requirements, related to ASU 2018-11.

15.3.2.3 Amount Lessor Expects to Derive From the Underlying Asset After the End of the Lease Term

ASC 842-30

50-3 A lessor shall disclose both of the following: . . .

b. Information about significant assumptions and judgments made in applying the requirements of this Topic, which may include the following: . . .

3. The determination of the amount the lessor expects to derive from the underlying asset following the end of the lease term.

An entity considers various inputs when evaluating the amount it expects to derive from its leased assets at the end of the lease terms, including the following:

The remaining useful life.
Expected market conditions:
- Fair value of lease payments.
- Expected fair values of underlying assets.
Expected deployment of underlying asset in business (e.g., re-lease or sell).

The estimated amount of the residual asset directly affects the gain (in a sales-type lease) or loss (in either a sales-type or a direct financing lease) the entity recognizes upon commencement of the lease. Therefore, this estimate and any related assumptions should be disclosed because they are critical to a user’s understanding of the amount of the gain or loss recognized and potential future cash flows.

15.3.2.4 Practical-Expedient Disclosure Related to Not Separating Lease and Nonlease Components

ASC 842-30

Its accounting policy election and the class or classes of underlying assets for which it has elected to apply the practical expedient
The nature of:
1. The lease components and nonlease components combined as a result of applying the practical expedient
2. The nonlease components, if any, that are accounted for separately from the combined component because they do not qualify for the practical expedient
The Topic the entity applies to the combined component (this Topic or Topic 606).

When a lessor elects the practical expedient to combine lease and nonlease components in a contract, it is required to provide certain disclosures. Such disclosures include (1) the lessor’s election to combine lease components with associated nonlease components, (2) the class(es) of underlying asset(s) for which the election was made, (3) the nature of the items that are being combined, (4) any nonlease components that were not eligible for the practical expedient, and (5) which standard applies to the combined component (i.e., ASC 842 or ASC 606). (See Section 4.3.3.2 for further discussion of this practical expedient.)

15.3.3 Lease Transactions With Related Parties

ASC 842-30

50-4 A lessor shall disclose any lease transactions between related parties (see Topic 850 on related party disclosures).

Lessors should disclose lease transactions between related parties in a manner consistent with the guidance in ASC 850. In accordance with ASC 850, a lessor should consider disclosing the nature of the related-party lease, the related-party relationship, and the terms of the lease that are affected by the relationship.

See Chapter 17 for a discussion of ASU 2023-01, which provides guidance on leasing arrangements between entities under common control.

15.3.4 Residual Assets and Risk Management

ASC 842-30

50-7 A lessor shall disclose information about how it manages its risk associated with the residual value of its leased assets. In particular, a lessor should disclose all of the following:

Its risk management strategy for residual assets
The carrying amount of residual assets covered by residual value guarantees (excluding guarantees considered to be lease payments for the lessor, as described in paragraph 842-30-30-1(a)(2))
Any other means by which the lessor reduces its residual asset risk (for example, buyback agreements or variable lease payments for use in excess of specified limits).

Paragraph BC331 of ASU 2016-02 describes the FASB’s rationale for including the above disclosure requirements related to residual assets in ASC 842-30-50-7:

While users generally said that the lessor accounting model in previous GAAP provided them with the financial information they needed, many users indicated that they needed more information about the lessor’s residual assets and exposure to residual asset risk. The latter (exposure to residual asset risk) is addressed by the lessor disclosure requirements discussed in paragraphs BC339 and BC340. Regarding the former (information about the lessor’s residual assets), the Board noted that users will benefit from the disclosure of a lessor’s unguaranteed residual assets separate from the lessor’s lease receivable. That is, because, although linked, those assets (that is the unguaranteed residual asset and the lease receivable) have different natures, risks, and liquidity. Separate disclosure of those assets will improve the transparency of information provided to users of financial statements about a lessor’s exposure to credit risk (relating to the lease receivable, which includes any guaranteed portion of the underlying assets’ estimated residual value) and asset risk (relating to the unguaranteed residual asset).

Further, paragraph BC340 of ASU 2016-02 states the following regarding the Board’s reasoning behind changing the previous U.S. GAAP guidance on this topic:

A primary concern of users on the disclosure requirements in previous GAAP is the lack of transparency about how the lessor manages its exposure to residual value risk. While users generally said that the lessor accounting model in previous GAAP provided them with the financial information they needed, many users indicated that additional information was needed about the lessor’s residual assets and exposure to residual risk. Uncertainty about the residual value of the underlying asset at the end of the lease is a lessor’s primary risk, particularly for a lessor of equipment and vehicles. This is because a decline in the market value of leased equipment and vehicles at a rate greater than the rate the lessor projected (on the basis of its policy on residual value measurement) would adversely affect the profitability of the lease. Residual value realization at the end of the lease term might be affected by several factors (for example, rapid technological or economic obsolescence, unusual wear and tear, excess use, or manufacturer’s warranties). Consequently, the Board decided that a lessor should disclose how it manages its residual value risk to enable users to assess the uncertainty of cash flows arising from a lessor’s leases and from its leased assets. The Board considered that producing residual risk disclosures will carry an incremental cost to preparers, but it decided to require the disclosures on the basis that this is an area in which users have consistently requested additional information and told the Board that the financial reporting for lessors in previous GAAP was inadequate for their information needs in many cases.

Connecting the Dots

Disclosures About Residual Asset Risk May Not Be as Applicable to Lessors of Real Estate

Residual value risk might not be a primary risk for many lessors of property (i.e., land or buildings in this context) because of the long-lived nature of those assets as well as the propensity for such assets to hold their value or, in many cases, to appreciate. In such cases, a lessor may consider providing more limited narrative disclosures.

15.3.5 Amounts Recognized in the Financial Statements

15.3.5.1 Sales-Type Leases and Direct Financing Leases

15.3.5.1.1 Tabular Disclosures

ASC 842-30

50-5 A lessor shall disclose lease income recognized in each annual and interim reporting period, in a tabular format, to include the following:

a. For sales-type leases and direct financing leases:

1. Profit or loss recognized at the commencement date (disclosed on a gross basis or a net basis consistent with paragraph 842-30-45-4)

2. Interest income either in aggregate or separated by components of the net investment in the lease. . . .

The table below outlines information that an entity would need to disclose for sales-type or direct financing leases to comply with the requirements in ASC 842-30-50-5 above.

	Lessor Uses Leasing to “Sell” PP&E It Would Otherwise Sell
	Sales-Type Lease	Direct Financing Lease
Selling profit at lease commencement	Gross selling price, cost of leased property, selling profit	Not applicable — no selling profit is recognized at lease commencement for direct financing leases
Selling loss	Gross selling price, cost of leased property, selling loss
Interest income	Disclose interest income either in aggregate or separated by components of the net investment in the lease. That is, disclose interest income related to (1) the interest earned on the lease receivable and (2) the accretion of the unguaranteed residual value of the asset.	Disclose interest income either in the aggregate or separated by components of the net investment in the lease. That is, disclose interest income related to (1) the interest earned on the lease receivable, (2) the accretion of the unguaranteed residual value of the asset, and (3) any deferred selling profit included in the net investment balance.

	Lessor Uses Leasing to Provide Financing to Lessees
	Sales-Type Lease	Direct Financing Lease
Selling profit at lease commencement	Selling profit	Not applicable — no selling profit is recognized at lease commencement for direct financing leases
Selling loss	Selling loss
Interest income	Disclose interest income either in aggregate or separated by components of the net investment in the lease. That is, disclose interest income related to (1) the interest earned on the lease receivable and (2) the accretion of the unguaranteed residual value of the asset.	Disclose interest income either in the aggregate or separated by components of the net investment in the lease. That is, disclose interest income related to (1) the interest earned on the lease receivable, (2) the accretion of the unguaranteed residual value of the asset, and (3) any deferred selling profit included in the net investment balance.

Example 15-1

Disclosures Related to Sales-Type Lease

The following disclosures are based on the calculations in Section 9.3.7:

Example 15-2

Disclosures Related to Direct Financing Lease

The following disclosures are based on the calculations in Section 9.3.8:

15.3.5.1.2 Components of Net Investments in Leases

ASC 842-30

50-6 A lessor shall disclose in the notes the components of its aggregate net investment in sales-type and direct financing leases (that is, the carrying amount of its lease receivables, its unguaranteed residual assets, and any deferred selling profit on direct financing leases).

The following is an example of a disclosure an entity might provide to comply with the above requirement in ASC 842-30-50-6 regarding disclosure of components of net investments in leases:

Changing Lanes

ASC 842 Amends Disclosure Requirements Pertaining to the Components of Net Investments in Leases

Under ASC 840-30-50-4, all of the following components of the net investment in sales-type or direct financing leases were disclosed: (1) future minimum lease payments to be received (with certain separate deductions), (2) unguaranteed residual values accruing to the lessor’s benefit, (3) initial direct costs (for direct financing leases only), and (4) unearned income. Unearned income in a sales-type lease was initially measured as the difference between the gross investment in the lease and the sum of the present values of the two components of the gross investment. Unearned income in a direct financing lease was initially measured as the difference between the gross investment in the lease and the cost or carrying amount of the underlying asset. Accordingly, under ASC 840, disclosures about the components of the net investment in a sales-type or a direct financing lease needed to include the gross amount of the components, with an unearned income adjustment to arrive at a total that corresponded to the balance sheet amount. On the other hand, ASC 842 requires that the carrying amount of the components of the net investment be disclosed. That is, each individual component should be presented at a discounted value.

15.3.5.1.3 Significant Changes in the Balance of Unguaranteed Residual Assets and Deferred Selling Profit

ASC 842-30

50-9 A lessor shall explain significant changes in the balance of its unguaranteed residual assets and deferred selling profit on direct financing leases.

Significant changes in the “balance of [a lessor’s] unguaranteed residual assets and deferred selling profit on direct financing leases” must be disclosed and could arise from fluctuations in the residual asset value governed by technological or other market influences, termination or completion of the lease, or impairment of the underlying asset.

15.3.5.1.4 Maturity Analysis of Lease Receivables

ASC 842-30

50-10 A lessor shall disclose a maturity analysis of its lease receivables, showing the undiscounted cash flows to be received on an annual basis for a minimum of each of the first five years and a total of the amounts for the remaining years. A lessor shall disclose a reconciliation of the undiscounted cash flows to the lease receivables recognized in the statement of financial position (or disclosed separately in the notes).

The below example3 includes a maturity analysis of lease receivables as well as a reconciliation to the total amount of receivables recognized in the statement of financial position.

15.3.5.2 Operating Leases

A lessor should treat assets subject to operating leases as a major class of depreciable assets. Specifically, paragraph BC341 of ASU 2016-02 states, in part:

[A] lessor should provide the required property, plant, and equipment disclosures for assets subject to operating leases separately from owned assets held and used by the lessor. In the Board’s view, leased assets often are subject to different risks than owned assets that are held and used (for example, the decrease in the value of the underlying asset in a lease could be due to several factors that are not within the control of the lessor), and, therefore, users will benefit from lessors segregating their disclosures related to assets subject to operating leases from disclosures related to other owned property, plant, and equipment.

15.3.5.2.1 Tabular Disclosures

ASC 842-30

50-5 A lessor shall disclose lease income recognized in each annual and interim reporting period, in a tabular format, to include the following: . . .

b. For operating leases, lease income relating to lease payments. . . .

In interim and annual reporting periods, a lessor should disclose, within its tabular disclosure of lease income, lease income related to lease payments from operating leases.

15.3.5.2.2 Maturity Analysis of Lease Payments

ASC 842-30

50-12 A lessor shall disclose a maturity analysis of lease payments, showing the undiscounted cash flows to be received on an annual basis for a minimum of each of the first five years and a total of the amounts for the remaining years. A lessor shall present that maturity analysis separately from the maturity analysis required by paragraph 842-30-50-10 for sales-type leases and direct financing leases.

With respect to the requirement in ASC 842-30-50-12 for a lessor to disclose a maturity analysis of operating lease payments, a reconciliation of the cash flows to the receivable balance is not required because a receivable similar to that recorded under a direct financing or sales-type lease is not recorded under an operating lease. (See Section 15.3.5.1.4.)

15.3.5.2.3 Separate ASC 360 Disclosures

ASC 842-30

50-13 A lessor shall provide disclosures required by Topic 360 on property, plant, and equipment separately for underlying assets under operating leases from owned assets.

To comply with the disclosure requirement above, an entity will need to consider the disclosure requirements in ASC 360-10-50, including those related to items such as depreciation, balances of major classes of assets, and impairment considerations.

15.3.5.3 Variable Lease Income

ASC 842-30

50-5 A lessor shall disclose lease income recognized in each annual and interim reporting period, in a tabular format, to include the following: . . .

c. Lease income relating to variable lease payments not included in the measurement of the lease receivable.

In interim and annual reporting periods, a lessor should disclose, within its tabular disclosure of lease income, lease income related to variable lease payments. This amount should include variable lease income associated with all lease classifications, but it should exclude any lease income already disclosed within the sales-type lease, direct-financing lease, or operating lease disclosures (i.e., it should exclude lease income related to payments included in the measurement of the lease receivable or in the calculation of straight-line operating lease income).

15.3.6 Practical-Expedient Disclosure Related to Sales Taxes and Other Similar Taxes Collected From Lessees

ASC 842-30

50-14 A lessor that makes the accounting policy election in paragraph 842-10-15-39A shall disclose its accounting policy election and comply with the disclosure requirements in paragraphs 235-10-50-1 through 50-6.

When a lessor elects, as an accounting policy, to exclude from revenue and expenses sales taxes and other similar taxes assessed by a governmental authority and collected by the lessor from a lessee, it should disclose that it has done so. See Section 17.3.1.5 for detailed discussion of ASU 2018-20, including transition requirements.

Footnotes

Assume that the lessor has one lease with a remaining lease term of six years and annual lease payments of $9,500.

Confidential and Proprietary — for Use Solely by Authorized Personnel

This publication provides comprehensive guidance; however, it does not address all possible fact patterns, and the guidance is subject to change. Consult a Deloitte & Touche LLP professional regarding your specific issues and questions.