5.8 Examples Illustrating the Determination of the Pattern of Reversals of Temporary Differences
The following examples describe several types of temporary differences and provide some
common methods (i.e., for illustrative purposes only) for determining the pattern of
their reversal. Other methods may also be acceptable if they are consistent with the
guidance in ASC 740-10-55 on determining reversal patterns.
5.8.1 State and Local Tax Jurisdictions
In the computation of an entity’s U.S. federal income tax liability,
income taxes that are paid to a state or municipal jurisdiction are deductible.
Thus, ASC 740-10-55-20 states, in part:
[A] deferred state [or municipal] income
tax liability or asset gives rise to a temporary difference for purposes of
determining a deferred U.S. federal income tax asset or liability, respectively.
The pattern of deductible or taxable amounts in future years for temporary
differences related to deferred state [or municipal] income tax liabilities or
assets should be determined by estimates of the amount[s] of those state [and
local] income taxes that are expected to become . . . deductible or taxable for
U.S. federal tax purposes in those particular future years.
5.8.2 Unrecognized Tax Benefits
Under the tax law, an entity may have a basis for deductions (e.g., repair expenses)
and may have accrued a liability for the probable disallowance of those deductions
(a UTB). If such deductions are disallowed, they would be capitalized for tax
purposes and would then be deductible in later years. ASC 740-10-55-21 states that
the accrual of the liability in this situation “has the effect of [implicitly]
capitalizing those expenses for tax purposes” and that those “expenses are
considered to result in deductible amounts in the later years” in which, for tax
purposes, the deductions are expected to be allowed. Moreover, this paragraph states
that “[i]f the liability for unrecognized tax benefits is based on an overall
evaluation of the technical merits of the tax position, scheduling should reflect
the evaluations made in determining the liability for unrecognized tax benefits that
was recognized.”
The change in the timing of taxable income or loss caused upon the disallowance of
expenses may affect an entity’s realization assessment of a DTA recognized for the
tax consequences of deductible temporary differences, operating loss, and tax credit
carryforwards. For example, upon disallowance of those expenses, taxable income for
that year will be higher. Similarly, taxable income for years after the disallowance
will be lower because the deductions are being amortized against taxable income in
those years. An entity should consider the impact of disallowance in determining
whether realization of a DTA meets the more-likely-than-not recognition threshold in
ASC 740.
5.8.3 Accrued Interest and Penalties
An entity that takes an aggressive position in a tax return filing often will accrue
a liability in its financial statements for interest and penalties that it would
incur if the tax authority successfully challenged that position. Such an entity
should schedule a deductible amount for the accrued interest for the future year in
which that interest is expected to become deductible as a result of settling the
underlying issue with the tax authority.
Because most tax jurisdictions do not permit deductions for penalties, a temporary
difference does not generally result from the accrual of such amounts for financial
reporting purposes.
5.8.4 Tax Accounting Method Changes
ASC 740-10-55-59 states, in part, that a “change in tax law may
require a change in accounting method for tax purposes, for example, the uniform
cost capitalization rules required by the Tax Reform Act of 1986.” Under the uniform
capitalization rules, calendar-year entities revalued “inventories on hand at the
beginning of 1987 . . . as though the new rules had been in effect in prior years.”
The resulting adjustment was included in the determination of taxable income or loss
over not more than four years. ASC 740-10-55-58 through 55-62 indicate that the
uniform capitalization rules initially gave rise to two temporary differences.
ASC 740-10-55-60 and 55-61 describe these two temporary differences as follows:
One temporary difference is related to the additional amounts initially
capitalized into inventory for tax purposes. As a result of those additional
amounts, the tax basis of the inventory exceeds the amount of the inventory
for financial reporting. That temporary difference is considered to result
in a deductible amount when the inventory is expected to be sold. Therefore,
the excess of the tax basis of the inventory over the amount of the
inventory for financial reporting as of December 31, 1986, is considered to
result in a deductible amount in 1987 when the inventory turns over. As of
subsequent year-ends, the deductible temporary difference to be considered
would be the amount capitalized for tax purposes and not for financial
reporting as of those year-ends. The expected timing of the deduction for
the additional amounts capitalized in this example assumes that the
inventory is not measured on a LIFO basis; temporary differences related to
LIFO inventories reverse when the inventory is sold and not replaced as
provided in paragraph 740-10-55-13.
The other temporary difference is related to the deferred income for tax
purposes that results from the initial catch-up adjustment. As stated above,
that deferred income likely will be included in taxable income over four
years. Ordinarily, the reversal pattern for this temporary difference should
be considered to follow the tax pattern and would also be four years. This
assumes that it is expected that inventory sold will be replaced. However,
under the tax law, if there is a one-third reduction in the amount of
inventory for two years running, any remaining balance of that deferred
income is included in taxable income for the second year. If such inventory
reductions are expected, then the reversal pattern will be less than four
years.
5.8.5 LIFO Inventory
ASC 740-10-55-13 states:
The particular years in which temporary differences
result in taxable or deductible amounts generally are determined by the timing
of the recovery of the related asset or settlement of the related liability.
However, there are exceptions to that general rule. For example, a temporary
difference between the tax basis and the reported amount of inventory for which
cost is determined on a [LIFO] basis does not reverse when present inventory is
sold in future years if it is replaced by purchases or production of inventory
in those same future years. A LIFO inventory temporary difference becomes
taxable or deductible in the future year that inventory is liquidated and not
replaced.
For most entities, an assumption that inventory will be replaced through purchases or
production does not ordinarily present difficulty. However, if there is doubt about
the ability of an entity to continue to operate as a going concern, the entity
should evaluate available evidence to determine whether it can make this assumption
when measuring DTAs and DTLs under ASC 740. The ability to assume that inventory can
be replaced might affect the recognition of a DTA when realization depends primarily
on the reversal of a taxable temporary difference. For example, if an entity is
unable to replace inventory because of financial or operating difficulties, a
taxable temporary difference resulting from LIFO inventory accounting would reverse
at that time and not be available to offset the tax consequences of future
deductions for retirement benefits that have been accrued for financial reporting
purposes but that will become deductible many years in the future when the benefits
are paid.
5.8.6 Obsolete Inventory
For financial reporting purposes, inventory may be written down to
net realizable value (e.g., when obsolescence occurs). Generally, for tax purposes,
the benefit of such a write-down cannot be realized through deductions until
disposition of the inventory. Thus, in such circumstances, there is a deductible
temporary difference between the reported amount of inventory and its underlying tax
basis. This temporary difference should be assumed to be deductible in the period in
which the inventory deductions are expected to be claimed (i.e., in the period in
which the inventory dispositions occur).
5.8.7 Cash Surrender Value of Life Insurance
Under ASC 325-30, an asset is recognized for financial reporting purposes in the
amount of the cash surrender value of life insurance purchased by an entity. ASC
740-10-25-30 cites the “excess of cash surrender value of life insurance over
premiums paid” as an example of a basis difference that “is not a temporary
difference if the [cash surrender value] is expected to be recovered without tax
consequence upon the death of the insured.” If, however, the policy is expected to
be surrendered for its cash value, the entity would include in taxable income any
excess cash surrender value over the cumulative premiums paid (note that the tax
basis in the policy is generally equal to cumulative premiums paid). The resulting
taxable temporary difference should be scheduled to reverse in the year in which the
entity expects to surrender the policy.
5.8.8 Land
The financial reporting basis of the value assigned to land may differ from the tax
basis. Such a difference may result from (1) property acquired in a nontaxable
business combination, (2) differences between capitalized costs allowable under
accounting standards and those allowable under tax law, or (3) property recorded at
predecessor cost for financial reporting purposes because it was acquired through a
transaction among entities under common control. Regardless of the reason for the
difference, the entity should assume that the temporary difference will reverse in
the year in which the land is expected to be sold to an unrelated third party;
otherwise, the timing of the reversal would be indefinite.
5.8.9 Nondepreciable Assets
In some jurisdictions, certain office buildings and other real estate cannot be
depreciated under local tax law. The tax authority may permit the tax basis of such
property to be routinely increased for the approximate loss in purchasing power
caused by inflation. The tax basis, as adjusted for indexing, is used to measure the
capital gain or loss. For financial reporting purposes, depreciation is recognized
on such assets. The effects of indexing for tax purposes and depreciation for
financial reporting purposes create deductible temporary differences that reverse
upon disposition of the associated assets.
5.8.10 Assets Under Construction
For financial reporting purposes, the carrying amount and tax basis of an asset under
construction for an entity’s own use may differ as a result of differences in
capitalized costs (e.g., interest capitalized under ASC 835-20 may differ from the
amount to be capitalized for tax purposes). The difference between the amount
reported for construction in progress for financial reporting purposes and its
related tax basis should be scheduled to reverse over the expected depreciable life
of the asset, which should not commence before the date on which the property is
expected to be placed into service.
5.8.11 Disposal of Long-Lived Assets by Sale
A deductible temporary difference results when, under ASC 360-10-35-37, a loss is
recognized for a write-down to fair value less costs to sell for assets to be
disposed of by sale. Because the deductions for losses cannot generally be applied
to reduce taxable income until they occur, the temporary difference should be
assumed to reverse during the period(s) in which such losses are expected to be
deductible for tax purposes.
5.8.12 Costs Associated With Exit or Disposal Activities
Under ASC 420, the fair value of certain exit or disposal costs (e.g., contract
termination) is recorded on the date the activity is initiated (e.g., contract
termination date) and is accreted to its settlement amount on the basis of the
discount rate initially used to measure the liability. Generally, an entity cannot
apply the deductions for exit or disposal activities to reduce taxable income until
they occur; therefore, the resulting deductible temporary differences should be
scheduled to reverse during the period(s) in which such losses are expected to be
deductible for tax purposes.
5.8.13 Loss Contingencies
Under ASC 450, the estimated losses on contingencies that are accrued for financial
reporting purposes when it is probable that a liability has been incurred and the
amount of the loss can be reasonably estimated are not deductible for tax purposes
until paid. The resulting deductible temporary differences should be scheduled to
reverse during the periods in which the losses are expected to be deductible for tax
purposes.
5.8.14 Organizational Costs
In the U.S. federal tax jurisdiction, an entity generally uses the
straight-line method to defer organizational costs and amortize them to income over
five years. Such costs are recognized as an expense for financial reporting purposes
in the period in which they are incurred unless an entity can clearly demonstrate
that the costs are associated with a future economic benefit. If the costs are
reported as an expense in the period in which they are incurred, any deductible
temporary differences should be scheduled to reverse on the basis of the future
amortization of the tax basis of the organizational asset recorded for tax
purposes.
5.8.15 Long-Term Contracts
Before the Tax Reform Act of 1986, use of the completed-contract
method for tax purposes resulted in significant temporary differences for many
entities that used the percentage-of-completion method for financial reporting
purposes. The Tax Reform Act of 1986 eliminated this use of the completed-contract
method (except for small contractors that are defined under the law), requiring that
an entity determine taxable income by using the percentage-of-completion method or a
hybrid of the completed-contract and percentage-of-completion methods for contracts
entered into after February 1986.
For entities that are permitted to continue using the completed-contract method for
tax purposes, a temporary difference will result in future taxable income in the
amount of gross profit recognized for financial reporting purposes. The reversal of
these differences would be assumed to occur on the basis of the period in which the
contract is expected to be completed.
If the percentage-of-completion method is used for both tax and financial reporting
purposes, temporary differences may nevertheless result because the gross profit for
tax purposes may be computed differently from how gross profit is computed for book
purposes. To schedule the reversals of these temporary differences, an entity would
generally need to estimate the amount and timing of gross profit for tax and
financial reporting purposes.
If a hybrid method is used for tax purposes and the percentage-of-completion method
is used for financial reporting purposes, the temporary differences might be
allocated between the portions of the contract that are accounted for under the
completed-contract method and those accounted for under the percentage-of-completion
method for tax purposes. Under this approach, the amount attributable to the use of
the completed-contract method for tax purposes might be scheduled to reverse,
thereby increasing taxable income, during the year in which the contract is expected
to be completed. The amount of temporary differences attributable to differences in
the percentage-of-completion methods for financial reporting and tax purposes might
be allocated and scheduled on the basis of the estimates of future gross profit for
financial reporting and tax purposes.
5.8.16 Pension and Other Postretirement Benefit Obligations
Under ASC 715, an employer generally recognizes the estimated cost of providing
defined benefit pension and other postretirement benefits to its employees over the
estimated service period of those employees. It records an asset or liability
representing the amount by which the present value of the estimated future cost of
providing the benefits either exceeds or is less than the fair value of plan assets
at the end of the reporting period.
Under U.S. tax law, however, an employer generally does not receive a deduction until
it makes a contribution to its pension plan or pays its other postretirement benefit
obligations (e.g., retiree medical costs). Because tax law generally precludes an
entity from taking deductions for these costs until the pension contribution is made
or the other postretirement benefit obligations are paid, the accounting required
under ASC 715 usually results in significant taxable or deductible temporary
differences for employers that provide such benefits.
ASC 715-30-55-4 and 55-5 explain that a taxable temporary difference related to an
overfunded pension obligation will reverse if (1) the plan is terminated to
recapture excess assets or (2) periodic pension cost exceeds future amounts funded.
For an overfunded obligation, we believe that the pattern of taxable amounts in
future years should generally be determined to be consistent with the pattern in
scenario (2). That is, we believe that the pattern of taxable amounts in future
years that will result from the temporary difference should generally be considered
the same as the pattern of estimated net periodic pension cost (as that term is
defined in ASC 715-30-20) for financial reporting for the following year and
succeeding years, if necessary, until future net periodic pension cost, on a
cumulative basis, equals the amount of the temporary difference. Under this
approach, additional employer contributions to the plan, if any, are ignored. It may
be estimated, however, that in early years, there will be net periodic pension
income (because the plan is significantly overfunded). If so, the existing
overfunded amount will not be recovered until the later years for which it is
estimated that there will be net periodic pension cost.
For an underfunded plan, the pattern of deductible amounts in future years that will
result from the temporary difference could be considered the same as the pattern by
which estimated future tax-deductible contributions are expected to exceed future
interest cost on the benefit obligation existing at the end of the reporting period.
This approach is similar to determining the pattern of reversals for other
discounted liabilities (e.g., amortizing a loan). Under this approach, each
estimated tax-deductible contribution to the plan in future years would be allocated
initially to (1) estimated future interest expense on the projected benefit
obligation existing at the end of the reporting period and then to (2) the projected
benefit obligation existing at the end of the reporting period.
5.8.17 Deferred Income and Gains
For tax purposes, certain revenue or income is taxed upon receipt of cash (e.g.,
rental income, loan, or maintenance fees received in advance). However, for
financial reporting purposes, such income is deferred and recognized in the period
in which the fee or income is earned. The amounts deferred in an entity’s balance
sheet will result in a deductible temporary difference because, for tax purposes, no
tax basis in the item exists.
Temporary differences from revenues or gains deferred for financial reporting
purposes, but not for tax purposes, should be assumed to result in deductible
amounts when the revenues or gains are expected to be earned or generated (i.e.,
when the deferred credit is expected to be settled).
5.8.18 Allowances for Doubtful Accounts
The Tax Reform Act of 1986 requires most taxpayers to use the specific charge-off
method to compute bad-debt deductions for tax purposes. For financial reporting
purposes, entities recognize loan losses in the period in which the loss is
estimated to occur. Such recognition creates a deductible temporary difference in
the amount of the allowance for doubtful accounts established for financial
reporting purposes. It is expected that an allowance for doubtful accounts as of the
current balance sheet date will result in deductible amounts in the year(s) in which
such accounts (1) are expected to be determined to be worthless for tax purposes or
(2) are planned to be sold (if held for sale).
5.8.19 Property, Plant, and Equipment
An entity might find it necessary to schedule the reversals of
temporary differences related to depreciable assets for two primary reasons: (1) to
assess whether it has sufficient taxable income of the appropriate character, within
the carryback/carryforward period available under the tax law, to conclude that
realization of a DTA is more likely than not and (2) to calculate the tax rate used
to measure DTAs and DTLs by determining the enacted tax rates expected to apply to
taxable income in the periods in which the DTLs or DTAs are expected to be settled
or realized. In each case, the entity must estimate the amounts and timing of
taxable income or loss expected in future years. Further, ASC 740-10-55-14 states,
in part, “For some assets or liabilities, temporary differences may accumulate over
several years and then reverse over several years. That pattern is common for
depreciable assets.”
Example 5-32
The following example illustrates the scheduling of temporary
differences for depreciable assets. Assume the following:
- An entity acquired depreciable assets for $1,000 at the beginning of 20X1.
- For financial reporting purposes, the property is depreciated on a straight-line basis over five years; for tax purposes, the modified accelerated cost recovery method is used.
-
The following table illustrates the depreciation schedules:
In December 20X1, the temporary difference of $150 (financial
statement carrying amount of $800 less tax basis of $650)
will result in a future net taxable amount. If the
originating differences are considered, the temporary
difference of $150 should be scheduled to reverse in the
following manner as of the end of 20X1:
If the entity does not consider future originating
differences to minimize the complexity of scheduling
reversal patterns, a first-in, first-out pattern would be
used and the $150 taxable temporary difference would be
scheduled as follows on December 31, 20X1: