Chapter 2 — Definitions of Discontinued Operation and Component of an Entity
Chapter 2 — Long-Lived Assets Classified as Held and Used
2.1 Overview
ASC 360-10
35-15
There are unique requirements of accounting for the
impairment or disposal of long-lived assets to be held and
used or to be disposed of. Although this guidance deals with
matters which may lead to the ultimate disposition of
assets, it is included in this Subsection because it
describes the measurement and classification of assets to be
held and used and assets held for disposal before actual
disposition and derecognition. See the Impairment or
Disposal of Long-Lived Assets Subsection of Section
360-10-40 for a discussion of assets or asset groups for
which disposition has taken place in an exchange or
distribution to owners.
Long-lived assets within the scope of ASC 360-10 are accounted for
and tested for impairment differently depending on the entity’s intent with regard
to the assets. Long-lived assets classified as held and used are those that the
entity intends to recover through use. Long-lived assets the entity intends to
recover through sale are classified as held and used until the held-for-sale
classification criteria are met (Chapter 3). Long-lived assets the entity intends to dispose of other
than by sale are classified as held and used until they are disposed of (Chapter 4).
ASC 360-10 contains a specific framework for accounting for long-lived assets
classified as held and used. Under ASC 360-10-35-21, long-lived assets that are
classified as held and used “shall be tested for recoverability whenever events or
changes in circumstances indicate that [their] carrying amount may not be
recoverable.” In addition, ASC 360-10-35-23 states that such assets “shall be
grouped with other assets and liabilities at the lowest level for which identifiable
cash flows are largely independent of the cash flows of other assets and
liabilities.”
In accordance with ASC 360-10-35-17, a long-lived asset (asset group) is not
recoverable if its carrying amount “exceeds the sum of the undiscounted cash flows
expected to result from the use and eventual disposition of the asset (asset
group).” When a long-lived asset (asset group) is not recoverable, it is necessary
to determine its fair value since “[a]n impairment loss shall be measured as the
amount by which the carrying amount of a long-lived asset (asset group) exceeds its
fair value.”
2.2 When to Test a Long-Lived Asset (Asset Group) for Recoverability
ASC 360-10
When to Test a Long-Lived Asset for Recoverability
35-21
A long-lived asset (asset group) shall be tested for
recoverability whenever events or changes in circumstances
indicate that its carrying amount may not be recoverable.
The following are examples of such events or changes in
circumstances:
-
A significant decrease in the market price of a long-lived asset (asset group)
-
A significant adverse change in the extent or manner in which a long-lived asset (asset group) is being used or in its physical condition
-
A significant adverse change in legal factors or in the business climate that could affect the value of a long-lived asset (asset group), including an adverse action or assessment by a regulator
-
An accumulation of costs significantly in excess of the amount originally expected for the acquisition or construction of a long-lived asset (asset group)
-
A current-period operating or cash flow loss combined with a history of operating or cash flow losses or a projection or forecast that demonstrates continuing losses associated with the use of a long-lived asset (asset group)
-
A current expectation that, more likely than not, a long-lived asset (asset group) will be sold or otherwise disposed of significantly before the end of its previously estimated useful life. The term more likely than not refers to a level of likelihood that is more than 50 percent.
ASC 360-10-35-21 requires that an entity test a long-lived asset (asset group) classified as held and used for impairment whenever “events or changes in circumstances indicate that its carrying amount might not be recoverable.” Such an event or change in circumstances is often referred to as a “triggering event.” The basis for this testing framework is described in paragraph B16 of the Background Information and Basis for Conclusions of FASB Statement 144, which states, in
part:
The Board concluded . . . that management has the responsibility to
consider whether an asset is impaired but that to test each asset each period
would be too costly. Existing information and analyses developed for management
review of the entity and its operations generally will be the principal evidence
needed to determine when an impairment exists. Indicators of impairment,
therefore, are useful examples of events or changes in circumstances that
suggest that the recoverability of the carrying amount of an asset should be
assessed.
Therefore, an entity is not required to perform recoverability tests
annually or regularly as it is for certain other assets like goodwill or
indefinite-lived intangible assets. However, an entity must continually assess
whether events or changes in circumstances indicate that long-lived assets may not
be recoverable.
ASC 360-10-35-21 gives examples of events or changes in circumstances that may
indicate that the carrying amount of a long-lived asset (group) may not be
recoverable. These examples are not all-inclusive; entities will need to assess
their specific facts and circumstances in determining whether there is a triggering
event. Additional events or changes in circumstances that an entity should consider
include:
- Evidence of a physical defect in an asset (asset group).
- Substantial doubt about an entityʼs ability to continue as a going concern.
- A significant change in technology that renders an asset (asset group) obsolete or noncompetitive.
- An impairment of goodwill.
- A significant stock price decline.
- Order cancellations or postponements from major customers, or both.
- Reduction in vacancy rate or rental income.
- A general economic downturn that is expected to have an impact on the entity.
The examples listed in ASC 360-10-35-21 include “a significant decrease in the market
price of a long-lived asset (asset group).” Therefore, the existence of an appraisal
or other independent valuation information that suggests that the fair value of a
held-and-used asset (asset group) is below its carrying amount may be an indicator
of impairment. However, the existence of such information does not, in and of
itself, mean that an impairment loss must be recognized since a recoverability test
must be performed on an undiscounted basis for the long-lived asset (asset group)
before recognition of any impairment loss (see Section
2.4).
An entity may be considering selling a part of its business but may
not yet meet the criteria to classify the related assets and liabilities as held for
sale (see Section 3.3
for more information). ASC 360-10-35-21(f) indicates that management should test the
long-lived assets (asset group) for recoverability if there is a “current
expectation that, more likely than not, a long-lived asset (asset group) will be
sold or otherwise disposed of significantly before the end of its previously
estimated useful life.” The threshold for “more likely than not” is considered to be
greater than 50 percent but less than probable. Therefore, an entity may be required
to test the long-lived assets it expects to sell for recoverability (i.e., on a
held-and-used basis) before the assets meet the criteria to be classified as held
for sale. The entity should also review depreciation estimates for an asset (asset
group) when impairment indicators exist (see Section 2.7).
In some cases, an entity may identify an impairment indicator for a specific asset
that is part of a larger asset group. If so, the entity should consider the
significance of that individual asset in relation to the asset group as a whole. If
the entity determines that the individual asset is insignificant to the asset group,
it may decide that it does not need to perform a recoverability test for the asset
group but should consider whether to revise the depreciation or amortization
estimate for that asset. However, an entity should not recognize an asset that has
no future benefit in its financial statements (see Section 2.8).
Connecting the Dots
In March 2021, the FASB issued ASU 2021-03, which allows private
companies and NFPs to use an accounting alternative for performing the
goodwill impairment triggering event evaluation. Specifically, the ASU gives
a private company or NFP the option of performing the goodwill impairment
triggering event evaluation required by ASC 350-20, as well as any resulting
goodwill impairment test, as of the end of the entity’s interim or annual
reporting period, as applicable.
The alternative provided by the ASU applies only to
monitoring goodwill for impairment triggering events; it does not change
existing requirements for private companies and NFPs to monitor their
long-lived assets and other assets for triggering events, and perform any
required impairment tests, during the reporting period.
2.3 Grouping Long-Lived Assets Classified as Held and Used
ASC 360-10
Grouping Long-Lived Assets Classified as Held and
Used
35-23 For
purposes of recognition and measurement of an impairment
loss, a long-lived asset or assets shall be grouped with
other assets and liabilities at the lowest level for which
identifiable cash flows are largely independent of the cash
flows of other assets and liabilities. However, an
impairment loss, if any, that results from applying this
Subtopic shall reduce only the carrying amount of a
long-lived asset or assets of the group in accordance with
paragraph 360-10-35-28.
Some long-lived assets may have largely independent cash flows and
therefore should be tested for impairment individually. However, many long-lived
assets are used in combination with other assets to generate combined cash flows in
such a way that the cash flows of each asset in the group are not largely
independent of the cash flows of other assets. In that case, entities must group
assets together to test them for impairment. Such a grouping is called an asset
group. The ASC master glossary defines an asset group as follows:
An asset group is the unit of accounting for a long-lived asset
or assets to be held and used, which represents the lowest level for which
identifiable cash flows are largely independent of the cash flows of other
groups of assets and liabilities.
Connecting the Dots
The term “asset group” is used throughout this publication
to refer to the long-lived asset or group of assets, including one or more
long lived assets and possibly liabilities, that is classified as held and
used and is being tested for impairment.
An asset group may include not only long-lived assets that are within the scope of
ASC 360-10 but also other assets such as receivables, inventory, indefinite-lived
intangible assets, or goodwill. (See Section
2.3.7 for information about the order in which impairment testing
should be performed when an asset group includes long-lived assets that are not
within the scope of ASC 360-10.)
An entity performing an impairment analysis should begin at the
lowest level for which there are largely independent cash flows; this level would
depend on the entity’s specific facts and circumstances (e.g., an individual
production line, real estate asset, plant, or retail store). Cash flows may be
grouped at a higher level only if the entity determines that largely independent
cash flows do not exist at a lower level. In determining the lowest level of
identifiable cash flows for a long-lived asset or asset group, the entity may need
to use significant judgment and should consider all relevant facts and
circumstances. Such facts and circumstances may include the following:
- The interdependency of revenue-generating activities and the extent to which such assets must be operated together.
- The interdependence or interchangeability of assets and the extent to which such assets are operated together.
- The presence and extent of a shared-cost structure.
- The extent to which the entity manages its business at various levels, such as a local, district, or regional management level.
- The entity’s distribution characteristics, such as regional distribution centers, local distributors, or individual plants.
- The extent to which purchases are made by an individual location or on a combined basis.
The degree to which the revenues of a group of assets depend on the
revenue-generating activities of other assets may affect an entity’s determination
of an asset group. Interdependency of revenues can result from the way an entity is
structured or from contractual requirements outside the entity’s control. If the
entity cannot suspend the revenue-generating activities of one group of assets
because of contractual or other restrictions outside the entity’s control, a
higher-level asset grouping may be justified.
ASC 360-10-55-35 and 55-36 contain an example illustrating a higher-level asset
grouping that is based on the interdependence of revenues in such a way that assets
must be operated together.
ASC 360-10
Example 4: Grouping Assets for Impairment
Review
55-35
Varying facts and circumstances will inevitably justify
different groupings of assets for impairment review. While
grouping at the lowest level for which there are
identifiable cash flows for recognition and measurement of
an impairment loss is understood, determining that lowest
level requires considerable judgment.
55-36
This Example illustrates the need for judgment in grouping
assets for impairment, as discussed in paragraphs
360-10-35-23 through 35-25. In this Example, an entity
operates a bus entity that provides service under contract
with a municipality that requires minimum service on each of
five separate routes. Assets devoted to serving each route
and the cash flows from each route are discrete. One of the
routes operates at a significant deficit that results in the
inability to recover the carrying amounts of the dedicated
assets. The five bus routes would be an appropriate level at
which to group assets to test for and measure impairment
because the entity does not have the option to curtail any
one bus route.
The degree to which an entity’s assets are interchangeable may also
affect its determination of asset groups. In some situations, largely identifiable
cash flows may not be associated with a specific asset group, in which case the
entity may be justified in grouping assets at a higher level. For example, if the
entity uses a fleet of interchangeable trucks, planes, or cargo ships to deliver
goods, the asset group might be at the fleet level if cash flows of an individual
asset cannot be identified.
A shared cost structure may affect an entity’s determination of its
asset groups. Shared costs are costs incurred by the entity that cannot be
identified or attributed to a specific asset group. If cash outflows from a group of
assets result from significant shared operating costs (e.g., shared sales force,
manufacturing, distribution, warehousing, research and development), it may be
necessary to group assets at a higher level. The entity should ensure that the
amount of shared costs is significant compared with its overall costs. For example,
a shared marketing function alone without other significant shared costs would not
be expected to justify a higher-level asset grouping. We do not believe that the
existence of shared back-office costs alone (e.g., finance, payroll, IT systems)
would support a higher-level asset grouping. Further, we think that shared operating
costs should be distinguished from allocated direct costs, which are costs that can
be directly associated with a specific asset group but may be recognized at the
corporate level for administrative purposes. If allocated direct costs are related
to a specific asset group even though such costs may not be allocated for internal
reporting purposes, we believe that an entity should specifically allocate those
costs to the asset group when evaluating the cash flows of that asset group. In
addition, the entity should not consider those direct costs to be shared costs when
determining whether a significant portion of the cash flows is interrelated.
Assets and liabilities are grouped under U.S. GAAP for different purposes, and the
guidance on grouping assets varies. For example, ASC 350-20 requires entities to
group assets (and liabilities) into a reporting unit when testing goodwill for
impairment. The identification of an asset group for impairment under ASC 360-10
differs from the identification of a reporting unit under ASC 350-20. The
determinations of a reporting unit and asset group must be based on the respective
ASC requirements as well as on the entity’s specific facts and circumstances. An
asset group is often at a lower level than a reporting unit but in some cases may be
at the same level. However, we would not expect an asset group to be at a higher
level than a reporting unit.
An entity should ensure that it appropriately documents the judgments it uses in
determining asset groups. Asset-group determinations are subject to change on the
basis of changes in facts and circumstances (see Section
2.3.8).
Bridging the GAAP
Under IAS 36, assets are tested at the individual asset
level or, if it is not possible to estimate the recoverable amount of an
individual asset, at the cash-generating unit (CGU) level. A CGU is the
smallest group of assets generating cash inflows that are largely
independent of the cash inflows from other assets. Under U.S. GAAP, the
assessment of independent cash flows for an asset group is generally based
on the net cash flows (i.e., cash inflows and outflows). Under IAS 36,
however, the focus is exclusively on whether cash inflows are largely
independent. While the resulting outcomes are often the same under the two
sets of standards, the different requirements could lead to differences.
2.3.1 Entity-Wide Assets
ASC 360-10
35-24 In limited
circumstances, a long-lived asset (for example, a
corporate headquarters facility) may not have
identifiable cash flows that are largely independent of
the cash flows of other assets and liabilities and of
other asset groups. In those circumstances, the asset
group for that long-lived asset shall include all assets
and liabilities of the entity.
35-25 In limited
circumstances, an asset group will include all assets
and liabilities of the entity. For example, the cost of
operating assets such as corporate headquarters or
centralized research facilities may be funded by
revenue-producing activities at lower levels of the
entity. Accordingly, in limited circumstances, the
lowest level of identifiable cash flows that are largely
independent of other asset groups may be the entity
level. See Example 4 (paragraph 360-10-55-35).
Some long-lived assets may not have identifiable cash flows that
are largely independent of the cash flows of the entity’s other assets (and
liabilities). Under ASC 360-10-35-25, “the cost of operating assets such as
corporate headquarters or centralized research facilities may be funded by
revenue-producing activities at lower levels of the entity.” Accordingly, in
limited circumstances, such long-lived assets are evaluated for impairment on an
entity-wide level because largely independent cash flows do not exist for the
asset. In that case, the recoverability test estimates whether the entity, as a
whole, will generate cash flows sufficient to recover the carrying amount of all
of its assets.
An entity-wide asset is tested for recoverability after any required testing of lower-level asset groups is performed. Paragraph B46 of the Background Information and Basis for Conclusions of FASB Statement 144 describes
the residual approach as one method that an entity may use to test an
entity-wide asset for recoverability:
The cash flows used in
the recoverability test should be reduced by the carrying amounts of the
entity’s other assets that are covered by this Statement to arrive at the
cash flows expected to contribute to the recoverability of the asset being
tested. Not-for-profit organizations should include unrestricted
contributions to the organization as a whole that are a source of funds for
the operation of the asset.
Therefore, under the residual approach, the entity compares (1)
the carrying amount of the entity-wide asset with (2) the cash flows available
to support the entity-wide asset calculated as the total undiscounted cash flows
for the entire entity less the carrying amounts of the lower-level asset groups.
If (1) is greater than (2), the entity would need to perform the second step of
the recoverability test for the entity-wide asset.
Example 2-1
Entity A grouped its long-lived assets for impairment
testing into (1) asset groups AG-1 and AG-2, for which
identifiable cash flows are largely independent of the
cash flows of other assets and liabilities, and (2)
asset group AG-EW, which consists of an entity-wide
information technology system long-lived asset that does
not have identifiable cash flows. The carrying amount of
AG-EW is $450.
Entity A has identified
events and circumstances indicating that the carrying
amounts of AG-2 and AG-EW might not be recoverable.
Entity-wide assets are tested for recoverability after
any required testing of lower-level asset groups. Entity
A first considers recoverability of both AG-1 and AG-2
as follows:
On the basis of the recoverability test,
A determines that AG-2 is not recoverable and recognizes
an impairment loss of $400.
Then, A
applies the residual approach to test AG-EW for
recoverability. For simplicity, in this example, it is
assumed that no cash outflows are associated with AG-EW.
The calculation under the residual approach is as
follows:
On the basis of the recoverability test
for AG-EW, A determines that AG-EW is recoverable; no
impairment is recorded for AG-EW.
2.3.2 Goodwill in Asset Groups
ASC 360-10
Effect of Goodwill When Grouping
35-26 Goodwill shall be
included in an asset group to be tested for impairment
under this Subtopic only if the asset group is or
includes a reporting unit. Goodwill shall not be
included in a lower-level asset group that includes only
part of a reporting unit. Estimates of future cash flows
used to test that lower-level asset group for
recoverability shall not be adjusted for the effect of
excluding goodwill from the group. The term reporting
unit is defined in Topic 350 as the same level as or one
level below an operating segment. That Topic requires
that goodwill be tested for impairment at the reporting
unit level.
35-27 Other than goodwill,
the carrying amounts of any assets (such as accounts
receivable and inventory) and liabilities (such as
accounts payable, long-term debt, and asset retirement
obligations) not covered by this Subtopic that are
included in an asset group shall be adjusted in
accordance with other applicable generally accepted
accounting principles (GAAP) before testing the asset
group for recoverability. Paragraph 350-20-35-31
requires that goodwill be tested for impairment only
after the carrying amounts of the other assets of the
reporting unit, including the long-lived assets covered
by this Subtopic, have been tested for impairment under
other applicable accounting guidance.
ASC 350-20
35-31 If goodwill and
another asset (or asset group) of a reporting unit are
tested for impairment at the same time, the other asset
(or asset group) shall be tested for impairment before
goodwill. For example, if a significant asset group is
to be tested for impairment under the Impairment or
Disposal of Long-Lived Assets Subsections of Subtopic
360-10 (thus potentially requiring a goodwill impairment
test), the impairment test for the significant asset
group would be performed before the goodwill impairment
test. If the asset group was impaired, the impairment
loss would be recognized prior to goodwill being tested
for impairment.
ASC 360-10-35-26 notes that goodwill is only included in an
asset group “if the asset group is or includes a reporting unit.” If the asset
group only includes part of a reporting unit, an entity would not include
goodwill in the carrying amount of the asset group when testing it for
impairment.
The guidance on including goodwill in an asset group that is classified as held
and used when it is tested for recoverability differs from the guidance in ASC
350-20-40-1 through 40-6 on assigning goodwill to a disposal group that is
classified as held for sale. Under ASC 350, goodwill must be assigned to a
disposal group that meets the definition of a business in accordance with ASC
805-10. However, for asset groups that are classified as held and used, goodwill
may not be included in an asset group if the assets are grouped below the
reporting unit level, even if the asset group itself meets the definition of a
business. (See Section 2.3.7 for more
information about the order for impairment testing when assets are classified as
held and used.)
2.3.3 Debt and Other Liabilities in Asset Groups
Debt related to the financing of long-lived assets should
generally be excluded from the asset group when it is tested for recoverability.
The entity’s financing decisions should not affect the outcome of the
recoverability test or the measurement of the fair value of an asset group.
Therefore, the lowest level of identifiable cash flows will generally exclude
principal and interest payments associated with debt because debt payments are
often made at the corporate level or at a level above the asset group. Further,
the cash flows associated with debt and interest payments are usually easy to
identify and typically can be eliminated from the cash flows used to test the
asset group for recoverability.
If debt is related to a specific asset or assets in the asset
group, it may be appropriate to include debt in the asset group. If debt is
included in the asset group, only the cash outflows related to principal
payments should be included in the cash outflows used to test the asset group
for recoverability. ASC 360-10-35-29 excludes interest charges that will be
recognized as an expense when incurred from the recoverability test to ensure
that two entities with essentially the same asset groups and cash flows do not
have different results for their recoverability testing solely because of
differences in their respective capital structures.
However, the inclusion or exclusion of debt and the related cash flows generally
would not result in a different conclusion in the recoverability test. That is,
debt with a carrying value of $500 will reduce the carrying amount of the asset
group by $500 but would also have related, undiscounted cash outflows of $500.
We believe that the same concept should also be applied to
liabilities other than debt. That is, operating liabilities are sometimes
included in the asset group because they are viewed as being related to the
assets in the group; however, nonoperating or financing liabilities are
generally excluded from the carrying amount of the asset group. Regardless of
whether a liability is included in or excluded from the asset group, the
associated cash flows should be determined consistently. For example, pension
obligations are often excluded from the carrying amount of the asset group. If
so, in estimating the cash flows of the asset group, an entity should only
include as an operating cash outflow the service cost component of the net
periodic pension costs, since the other components would be considered similar
to financing costs.
2.3.4 Right-of-Use Assets and Lease Liabilities in Asset Groups
ASC 360-10
15-4 The guidance in the
Impairment or Disposal of Long-Lived Assets Subsections
applies to the following transactions and activities:
- Except as indicated in (b) and the following
paragraph, all of the transactions and activities
related to recognized long-lived assets of an
entity to be held and used or to be disposed of,
including
- Right-of-use assets of lessees
- Long-lived assets of lessors subject to operating leases . . . .
ASC 842-20
35-9 A lessee shall determine
whether a right-of-use asset is impaired and shall
recognize any impairment loss in accordance with Section
360-10-35 on impairment or disposal of long-lived
assets.
A lessee must test an ROU asset for impairment in a manner
consistent with its treatment of other long-lived assets. In addition to the
discussion below, see Section
8.4.4 of Deloitte’s Roadmap Leases for more information about
an entity’s testing of ROU assets for impairment after the adoption of ASC 842.
2.3.4.1 Entity Is a Lessee in a Finance Lease
For the reasons described in Section
2.3.3, we believe that a lessee would generally exclude a
finance lease liability from the carrying amount of the asset group since
that liability is akin to debt. Because the finance lease obligation is
excluded from the asset group that includes the finance lease ROU asset, the
finance lease payments — both principal and interest — should not reduce the
undiscounted expected future cash flows used to test the asset group for
recoverability.
Therefore, when performing the recoverability test for an asset group that
includes a finance lease ROU asset, a lessee would exclude both (1) the
finance lease obligation from the carrying value of the asset group and (2)
the related lease payments from the undiscounted expected future cash flows.
This approach is consistent with how an entity performs the recoverability
test for capital lease assets recognized in accordance with ASC 840.
Further, if the asset group fails to pass the first step of the impairment
test, the lessee would also exclude the finance lease obligation from the
determination of the fair value of the asset group in the second step.
2.3.4.2 Entity Is a Lessee in an Operating Lease
Two views have emerged regarding how a lessee should determine the carrying
value of an asset group in performing the first step of the impairment test
for its operating leases:
- View 1 — Exclude the operating lease obligation from the carrying amount of the asset group. The basis for this view is that while the lease is classified as an operating lease, the arrangement is viewed as a financing transaction. Therefore, in a manner consistent with the treatment of the lease obligation for a finance lease, the operating lease obligation and related lease payments would be excluded from the first step of the impairment test. Accordingly, the operating lease payments (both principal and interest) would not reduce the undiscounted expected future cash flows used to test the asset group for recoverability.
- View 2 — Include the operating lease obligation in the carrying amount of the asset group. Because the lease is classified as an operating lease, the related liability is not considered to be a financial liability. Therefore, the operating lease obligation would be included in the determination of the carrying amount of the asset group and the undiscounted expected future cash flows. Accordingly, the operating lease payments should be included as cash outflows in the determination of the undiscounted cash flows for the recoverability test.
In addition, since the total lease expense in an operating lease is presented
as a single line item in the income statement, the lease payments include
both an interest component and a principal component. As a result, questions
have arisen regarding whether the cash outflows related to the operating
lease obligation should include only the portion related to principal or
that related to both principal and interest (i.e., the full payment). The
FASB discussed this topic at its November 30, 2016, meeting. The Board
generally agreed that lessees should exclude interest payments from
calculations of the undiscounted cash flows in the first step of the
impairment test. However, some Board members noted that a lessee’s decision
to include interest in its impairment analysis could be viewed as an
accounting policy election.
Therefore, under View 2, a lessee can use one of the following two approaches:
- View 2A — Include only the principal component of lease payments as cash outflows in the undiscounted cash flows of the asset group. This view takes into account how the undiscounted cash flows of a typical financial liability would be determined, which would only include the principal component of the payments. Therefore, in a manner consistent with the guidance in ASC 360-10-35-29, a lessee would exclude the interest component of the lease payments from the asset group’s undiscounted cash flows. This is consistent with the Board’s view described above.
- View 2B — Include the total operating lease payments as cash outflows in the undiscounted cash flows of the asset group. According to this view, the lease liability is not considered to be akin to a financial liability; therefore, in a manner similar to the income statement presentation of operating lease expense as a single lease cost, total operating lease payments are included in the undiscounted cash flows of the asset group.
If a lessee is required to perform the second step of the impairment test
because the asset group that includes an operating lease ROU asset fails to
pass the first step, the lessee should apply the same approach (i.e.,
maintain consistency regarding the inclusion or exclusion of the lease
liability) when calculating the fair value of the asset group in the second
step as the approach it used to determine the carrying amount of the asset
group in the first step. Therefore, if a lessee in an operating lease
excluded the lease liability when performing the first step of the
impairment test (i.e., View 1), the lessee should also exclude the lease
liability when determining the fair value of the asset group in the second
step of the impairment test. Alternatively, if the lessee included both the
ROU asset and lease liability when performing the first step of the
impairment test (i.e., View 2), the lessee should also include both the ROU
asset and lease liability when determining the fair value of the asset group
in the second step of the impairment test. Importantly, regardless of
whether an entity applied View 2A or 2B above when performing the first
step, the total lease payments should be used for the second step of the
impairment test because the cash flows used to determine the asset group’s
fair value will be discounted.
If the ROU asset related to an operating lease is impaired, the lessee would
amortize the remaining ROU asset in accordance with the
subsequent-measurement guidance that applies to finance leases — typically,
on a straight-line basis over the remaining lease term. Thus, the operating
lease would no longer qualify for the straight-line treatment of total lease
expense. However, in periods after the impairment, a lessee would continue
to present the ROU asset reduction and interest accretion related to the
lease liability as a single line item in the income statement.
2.3.5 Deferred Taxes in Asset Groups
While ASC 360-10 does not specify whether an entity should use pretax or post-tax
cash flows in its recoverability test, many entities perform the recoverability
test on a pretax basis. When the entity performs the test by using pretax cash
flows, deferred taxes should not be included in the carrying amount of the asset
group. Alternatively, if the entity performs the test by using post-tax cash
flows, the deferred taxes related to the asset group should be included in the
carrying amount of the asset group. The inclusion or exclusion of deferred taxes
and the related cash flows generally would not result in a different conclusion
in the recoverability test. That is, a deferred tax liability with a carrying
value of $200 will reduce the carrying amount of the asset group by $200 but
would be expected to have related, undiscounted cash outflows of $200.
In certain instances, tax amounts are directly related to the
assets in the asset group. For example, an entity may invest in projects that
receive tax incentives in the form of tax credits (e.g., affordable housing
projects, projects that produce energy or fuel from alternative, nonconventional
sources). The tax aspects of the asset change the economics of the decision to
invest in and operate the asset. In these instances, if the entity expects to
use the tax credits in its return, it may include the incremental cash flows
from the tax credits in the cash flow projection when assessing an asset’s
recoverability and measuring any impairment. Note that if the entity includes
the tax aspects of a transaction in determining the cash flows, it must ensure
that it is not recognizing the tax amounts twice in its cash flow
determinations.
2.3.6 Foreign Asset Groups and Accumulated Other Comprehensive Income, Including Foreign Currency Translation, in Asset Groups
ASC 830-30
45-13 An entity that has
committed to a plan that will cause the cumulative
translation adjustment for an equity method investment
or a consolidated investment in a foreign entity to be
reclassified to earnings shall include the cumulative
translation adjustment as part of the carrying amount of
the investment when evaluating that investment for
impairment. The scope of this guidance includes an
investment in a foreign entity that is either
consolidated by the reporting entity or accounted for by
the reporting entity using the equity method. This
guidance does not address either of the following:
- Whether the cumulative translation adjustment shall be included in the carrying amount of the investment when assessing impairment for an investment in a foreign entity when the reporting entity does not plan to dispose of the investment (that is, the investment or related consolidated assets are held for use)
- Planned transactions involving foreign investments that, when consummated, will not cause a reclassification of some amount of the cumulative translation adjustment.
45-14 In both cases,
paragraph 830-30-40-1 is clear that no basis exists to
include the cumulative translation adjustment in an
impairment assessment if that assessment does not
contemplate a planned sale or liquidation that will
cause reclassification of some amount of the cumulative
translation adjustment. (If the reclassification will be
a partial amount of the cumulative translation
adjustment, this guidance contemplates only the
cumulative translation adjustment amount subject to
reclassification pursuant to paragraphs 830-30-40-2
through 40-4.)
45-15 An entity shall
include the portion of the cumulative translation
adjustment that represents a gain or loss from an
effective hedge of the net investment in a foreign
operation as part of the carrying amount of the
investment when evaluating that investment for
impairment.
An entity performs the recoverability test in its functional
currency even if the asset group’s books of record are not maintained in the
entity’s functional currency (e.g., a foreign subsidiary whose local currency is
not the entity’s functional currency). Such circumstances could result in a
functional-currency impairment or the reversal of a local-currency
impairment.
ASC 830-30-45-13 states that “[a]n entity that has committed to
a plan that will cause the cumulative translation adjustment [CTA] for an equity
method investment or a consolidated investment in a foreign entity to be
reclassified to earnings shall include the [CTA] as part of the carrying amount
of the investment when evaluating that investment for impairment.” Therefore, an
entity should not include the CTA balance in the asset group when testing it for
recoverability on a held-and-used basis. (See Section 3.4.2 for more information about
including accumulated other comprehensive income [AOCI] in the disposal group
when the assets are held for sale.)
Although ASC 830-30-45-13 addresses foreign CTAs, there is no
specific U.S. GAAP guidance on how an entity should treat other items included
in AOCI (e.g., unrealized holding gains and losses on available-for-sale debt
securities, gains and losses related to postretirement benefits) when evaluating
an asset group for impairment. We believe that it is appropriate to analogize to
the guidance in ASC 830-30-45-13 for all items of AOCI.
For more information about testing a foreign entity for
impairment and the reclassification of the CTA out of equity, see Section 5.5 of
Deloitte’s Roadmap Foreign
Currency Matters.
2.3.7 Order of Impairment Testing When an Asset Group Is Held and Used
ASC 360-10
35-27 Other than goodwill,
the carrying amounts of any assets (such as accounts
receivable and inventory) and liabilities (such as
accounts payable, long-term debt, and asset retirement
obligations) not covered by this Subtopic that are
included in an asset group shall be adjusted in
accordance with other applicable generally accepted
accounting principles (GAAP) before testing the asset
group for recoverability. Paragraph 350-20-35-31
requires that goodwill be tested for impairment only
after the carrying amounts of the other assets of the
reporting unit, including the long-lived assets covered
by this Subtopic, have been tested for impairment under
other applicable accounting guidance.
As indicated in Section 2.3, an asset
group may include not only long-lived assets that are within the scope of ASC
360-10 but also other assets such as receivables, inventory, indefinite-lived
intangible assets, or goodwill. When assets other than long-lived assets are
present within an asset group, an entity needs to follow a required order when
testing the assets in the asset group for impairment. The following flowchart
illustrates the order in which an entity is required to test assets for
impairment when an asset group is classified as held and used:
This order ensures that the carrying amounts of any impaired
assets are adjusted before the carrying amount of the asset group is determined.
That is, it ensures that any impairments for assets that are tested for
impairment individually or at smaller units of account (e.g., receivables,
inventory, or indefinite-lived intangible assets) are recognized before assets
that are tested by using a larger unit of account. Therefore, an entity should
adjust the carrying amount of each asset, if necessary, before performing the
next impairment test. Further, ASU 2016-20 includes a
technical correction that amends ASC 340-40 to clarify that the order in which
assets should be tested for impairment is as follows: (1) assets outside the
scope of ASC 340-40 (e.g., inventory under ASC 330), (2) assets accounted for
under ASC 340-40, and (3) reporting units and asset groups under ASC 350 and ASC
360.
An entity would be expected to routinely assess for impairment,
under applicable GAAP, the assets that would be tested first (i.e., the assets
that are outside the scope of ASC 360-10 other than goodwill), regardless of
whether a triggering event occurs for the asset group. The fact that these
assets are part of an asset group does not change the process for testing them
for impairment.
As described further in Section 2.3.2, goodwill is only included
in an asset group “if the asset group is or includes a reporting unit” in
accordance with ASC 350-20-35-31. However, even if goodwill is not assigned to
an asset group, an entity should consider whether the existence of an impairment
indicator for one or more of its asset groups may suggest that goodwill is also
impaired.
Connecting the Dots
In March 2021, the FASB issued ASU 2021-03, which allows
private companies and NFPs to use an accounting alternative for
performing the goodwill impairment triggering event evaluation.
Specifically, the ASU gives a private company or NFP the option of
performing the goodwill impairment triggering event evaluation required
by ASC 350-20, as well as any resulting goodwill impairment test, as of
the end of the entity’s interim or annual reporting period, as
applicable.
The alternative provided by the ASU applies only to monitoring goodwill
for impairment triggering events; it does not change existing
requirements for private companies and NFPs to monitor their long-lived
assets and other assets for triggering events, and perform any required
impairment tests, during the reporting period. As a result, a private
company or NFP that has adopted ASU 2021-03 would not assess goodwill
for triggering events until the end of its next reporting period.
The entity should keep in mind that the required order for
testing long-lived assets and goodwill when an asset group is classified as held
and used differs from that when a disposal group is classified as held for sale
(see Section
3.5.1).
Connecting the Dots
The following is a list of assets that would be tested for impairment
before the asset group is tested:
- Accounts receivable (see ASC 310 and ASC 326).
- Inventory (see ASC 330-10-35).
- Intangible assets not being amortized that are to be held and used (i.e., indefinite-lived intangible assets) (see ASC 350-30-35).
- Internal-use software (see ASC 350-40-35).
- Servicing assets (see ASC 860-50-35).
- Loans (see ASC 310-10-35).
- Debt securities accounted for at fair market value, other than a temporary decline in the value of financial instruments accounted for at fair market value (see ASC 320-10-35).
- Equity securities, not recorded at fair value, without readily determinable fair values (see ASC 321-10-35).
- Equity method investments (see ASC 323-10-35).
- Mortgage banking assets (see ASC 948-310-35).
- Deferred policy acquisition costs (see ASC 944-60-25).
- Deferred tax assets (see ASC 740-10-30).
- Unproved oil and gas properties (see ASC 932-360-35).
- Entertainment — broadcasters’ assets (see ASC 920-350-35).
- Entertainment — cable television intangible assets not depreciated (see ASC 922-350-35).
- Entertainment — films (see ASC 926-20-35).
- Entertainment — music (see ASC 928-340-35).
- Costs of computer software to be sold, leased, or otherwise marketed (see ASC 985-20-35).
- Rate-regulated assets and regulated assets (see ASC 980).
- Sales-type, direct financing, and leveraged leases (see ASC 842 and ASC 326).
- Sale-leaseback transactions (see ASC 842 and ASC 326).
2.3.8 Changes in Asset-Group Determinations
Changes in asset-group determinations should be accounted for prospectively in a
manner similar to changes in estimate. Changes in asset-group determinations
might result when an entity undergoes a significant change in its operating or
reporting structure, has a significant acquisition or disposition, or
significantly changes the way in which it uses or deploys its assets.
2.4 Testing Long-Lived Assets for Recoverability
ASC 360-10
Long-Lived Assets Classified as Held and Used
35-16 This
guidance addresses how long-lived assets or asset groups
that are intended to be held and used in an entity’s
business shall be reviewed for impairment.
35-17 An
impairment loss shall be recognized only if the carrying
amount of a long-lived asset (asset group) is not
recoverable and exceeds its fair value. The carrying amount
of a long-lived asset (asset group) is not recoverable if it
exceeds the sum of the undiscounted cash flows expected to
result from the use and eventual disposition of the asset
(asset group). That assessment shall be based on the
carrying amount of the asset (asset group) at the date it is
tested for recoverability, whether in use (see paragraph
360-10-35-33) or under development (see paragraph
360-10-35-34). An impairment loss shall be measured as the
amount by which the carrying amount of a long-lived asset
(asset group) exceeds its fair value.
05-6 This
Subsection provides guidance that focuses on developing
estimates of future cash flows used to test for
recoverability, including the:
- Cash flow estimation approach
- Cash flow estimation period
- Types of asset-related expenditures that should be considered in developing estimates of future cash flows.
An asset group is not recoverable if its carrying amount “exceeds
the sum of the undiscounted cash flows expected to result from the use and eventual
disposition of the asset (asset group).” The process of determining whether an asset
group is recoverable is generally referred to as the “recoverability test.”
When an asset group is not recoverable, it is necessary to determine
its fair value since “an impairment loss shall be measured as the amount by which
the carrying amount of the long-lived asset (asset group) exceeds its fair value.”
If the asset group is determined to be recoverable, no impairment
loss is recognized even if the carrying value of the asset group exceeds its fair
value. However, even if the asset group is determined to be recoverable, an entity
should consider whether it should revise the depreciation or amortization estimates
for the long-lived assets in the group (see Section
2.7).
2.4.1 Estimates of Future Cash Flows Used to Test Long-Lived Assets for Recoverability
ASC 360-10
35-29
Estimates of future cash flows used to test the
recoverability of a long-lived asset (asset group) shall
include only the future cash flows (cash inflows less
associated cash outflows) that are directly associated
with and that are expected to arise as a direct result
of the use and eventual disposition of the asset (asset
group). Those estimates shall exclude interest charges
that will be recognized as an expense when incurred.
35-30
Estimates of future cash flows used to test the
recoverability of a long-lived asset (asset group) shall
incorporate the entity’s own assumptions about its use
of the asset (asset group) and shall consider all
available evidence. The assumptions used in developing
those estimates shall be reasonable in relation to the
assumptions used in developing other information used by
the entity for comparable periods, such as internal
budgets and projections, accruals related to incentive
compensation plans, or information communicated to
others. However, if alternative courses of action to
recover the carrying amount of a long-lived asset (asset
group) are under consideration or if a range is
estimated for the amount of possible future cash flows
associated with the likely course of action, the
likelihood of those possible outcomes shall be
considered. A probability-weighted approach may be
useful in considering the likelihood of those possible
outcomes. See Example 2 (paragraph 360-10-55-23) for an
illustration of this guidance.
ASC 360-10-35-29 states that “[e]stimates of future cash flows
used to test the recoverability of [an asset group should] include only the
future cash flows (cash inflows less associated cash outflows) that are directly
associated with and that are expected to arise as a direct result of the use and
eventual disposition of the [asset group].”
Certain costs that are directly attributable to a specific asset
group may be recognized at the corporate level for administrative purposes or
recognized by another part of the entity. Estimated future cash flows should
include all cash outflows necessary to support the cash inflows of the asset
group. Therefore, cash outflows should include an allocation of shared costs or
costs incurred by the entity on behalf of the asset group that are directly
attributable to the asset group even if such costs are not allocated to that
group for internal reporting purposes. For example, advertising expenses for a
fast-food chain may be identifiable with specific market areas or stores but may
be invoiced in the aggregate and recognized at the corporate level. Accordingly,
such advertising costs are directly attributable to the asset group and
therefore should be included in the asset group’s cash flow projections.
However, other expenses, such as corporate overhead, may not be directly
attributable to a particular asset group (e.g., the CEO’s salary or rent on the
corporate headquarters building).
Since the guidance in ASC 360-10 is relatively limited, an
entity may find it challenging and need to use judgment to identify which cash
flows to include in or exclude from the recoverability test.
2.4.1.1 Estimates of Future Cash Flows Are Undiscounted and Based on the Entity’s Expected Use of the Asset Group
The cash flows used in the recoverability test are
undiscounted and based on the entity’s own assumptions about its use and
eventual disposition of the asset group. Therefore, the cash flows
incorporate the entity’s intent regarding how it plans to recover the value
of the asset group rather than assessing how a market participant might use
and eventually dispose of the asset group. Accordingly, the cash flow amount
used in the recoverability test could differ from a fair value measurement
by more than just discounting. Entities are permitted to use either a
probability-weighted or a best estimate cash flow approach to test
long-lived assets for recoverability (see Section 2.4.3). However, if the entity
is considering alternative courses of action to recover an asset (e.g.,
either through sale or continued use), it may be useful for the entity, in
considering the likelihood of potential outcomes, to employ a
probability-weighted approach in which the possible scenarios are weighed on
the basis of the entity’s current expectations about the course of action it
will take to recover the assets.
Further, the cash flows used in the recoverability test should only include
cash flows associated with future expenditures (e.g., repairs and
maintenance and replacements) necessary to maintain the existing service
potential of the asset group (see Section
2.4.5 for more information).
The cash flows used in the recoverability test should be based only on facts
and circumstances available as of the testing date (see Section 2.4.2 for more details).
2.4.1.2 Estimates of Future Cash Flows Arising From the Eventual Disposition of the Asset Group
ASC 360-10-35-29 indicates that in the development of cash
flow estimates, the estimates of future cash flows should also include the
cash flows that are expected to arise from the eventual disposition of the
asset group. Therefore, the undiscounted cash flows should include any
estimated sales proceeds from the sale of the asset group at the end of the
cash flow estimation period.
The estimated sales proceeds represent the price the entity
would expect to receive for the asset group on the basis of its existing
service potential as of the assumed disposition date. The entity should use
assumptions that would maximize the proceeds that would be received in
selling the asset group. That is, in some cases, the asset group sold as a
whole would be assumed to receive a greater return than the sale of the
assets individually, or vice versa. In addition, an asset group that is a
business may be assumed to receive higher proceeds than an asset group that
is not a business. The cash flows from the sale of an asset group that is a
business generally represent the value of an operating business at the end
of the cash flow estimation period, while the cash flows from the sale of an
asset group that is not a business generally represent the salvage value of
the assets at the end of the cash flow estimation period. However, the
entity must continue to use entity-specific assumptions for the
recoverability test and should only assume proceeds on the basis of the
existing service potential and the entity’s use of the asset; such
assumptions could differ from market-participant assumptions in some cases.
Existing service potential does not mean that the entity should assume a
zero growth rate for the asset group; instead, any growth should be limited
to the asset groupʼs existing service potential. For example, the entity can
assume growth if its facilities have excess capacity and it can support its
projections for customer demand for its products. However, it would not be
appropriate to assume continued growth if the entityʼs facilities are
currently operating at maximum capacity and the building of an additional
facility would be required to achieve the projected growth.
2.4.1.3 Estimates of Future Cash Flows Should Be Reasonable
ASC 360-10 does not place any specific limits on the growth
assumptions used in the recoverability test. However, ASC 360-10-35-30
states that the assumptions used to develop cash flow estimates should be
“reasonable in relation to the assumptions used in developing other
information used by the entity for comparable periods, such as internal
budgets and projections, accruals related to incentive compensation plans,
or information communicated to others.” In addition, the entity should
ensure that the projections are consistent with budgets, forecasts, and
other information prepared by the entity such as those used to test goodwill
for impairment and to assess the recoverability of deferred tax assets.
However, such projections may differ when an entity has negative evidence in
the form of cumulative losses. (See Section
5.3.2.1 of Deloitte’s Roadmap Income Taxes for additional guidance on
developing objective and verifiable projections of taxable income when an
entity is in a cumulative loss.) Moreover, the entity should ensure that
such projections are in line with other data such as industry growth rates
and trends. Thus, if an entity has a reasonable basis for assuming that
prices or volumes will increase from current levels, it is appropriate for
the entity to reflect such growth assumptions in its cash flow estimates.
In SAB Topic 5.CC, the SEC staff expresses its views on an
entity’s judgments regarding the cash flows used in the recoverability
test.
SEC Staff Accounting Bulletins
SAB Topic 5.CC, Impairments [Reproduced in ASC
360-10-S99-2]
Question 3: Has the staff expressed any views
with respect to company-determined estimates of cash
flows used for assessing and measuring impairment of
assets under FASB ASC Topic 360?
Interpretive Response: In providing guidance
on the development of cash flows for purposes of
applying the provisions of that Topic, FASB ASC
paragraph 360-10-35-30 indicates that “estimates of
future cash flows used to test the recoverability of
a long-lived asset (asset group) shall incorporate
the entity’s own assumptions about its use of the
asset (asset group) and shall consider all available
evidence. The assumptions used in developing those
estimates shall be reasonable in relation to the
assumptions used in developing other information
used by the entity for comparable periods, such as
internal budgets and projections, accruals related
to incentive compensation plans, or information
communicated to others.”
The staff recognizes that various factors, including
management’s judgments and assumptions about the
business plans and strategies, affect the
development of future cash flow projections for
purposes of applying FASB ASC Topic 360. The staff,
however, cautions registrants that the judgments and
assumptions made for purposes of applying FASB ASC
Topic 360 must be consistent with other financial
statement calculations and disclosures and
disclosures in MD&A. The staff also expects that
forecasts made for purposes of applying FASB ASC
Topic 360 be consistent with other forward-looking
information prepared by the company, such as that
used for internal budgets, incentive compensation
plans, discussions with lenders or third parties,
and/or reporting to management or the board of
directors.
For example, the staff has reviewed a fact pattern
where a registrant developed cash flow projections
for purposes of applying the provisions of FASB ASC
Topic 360 using one set of assumptions and utilized
a second, more conservative set of assumptions for
purposes of determining whether deferred tax
valuation allowances were necessary when applying
the provisions of FASB ASC Topic 740, Income Taxes.
In this case, the staff objected to the use of
inconsistent assumptions.
In addition to disclosure of key assumptions used in
the development of cash flow projections, the staff
also has required discussion in MD&A of the
implications of assumptions. For example, do the
projections indicate that a company is likely to
violate debt covenants in the future? What are the
ramifications to the cash flow projections used in
the impairment analysis? If growth rates used in the
impairment analysis are lower than those used by
outside analysts, has the company had discussions
with the analysts regarding their overly optimistic
projections? Has the company appropriately informed
the market and its shareholders of its reduced
expectations for the future that are sufficient to
cause an impairment charge? The staff believes that
cash flow projections used in the impairment
analysis must be both internally consistent with the
company’s other projections and externally
consistent with financial statement and other public
disclosures.
Connecting the Dots
ASC 930-360-35-1 and 35-2 provide specific guidance on estimating
future cash flows (both undiscounted and discounted) to determine
whether a mining entity’s value beyond proven and probable reserves
is impaired:
35-1 An entity shall include the cash flows associated
with value beyond proven and probable reserves in estimates
of future cash flows (both undiscounted and discounted) used
for determining whether a mining asset is impaired under
paragraphs 360-10-15-3 through 15-5. Estimated cash flows
also shall include the estimated cash outflows required to
develop and extract the value beyond proven and probable
reserves.
35-2 An entity shall consider the effects of
anticipated fluctuations in the market price of minerals
when estimating future cash flows (both undiscounted and
discounted) used for determining whether a mining asset is
impaired under the Impairment or Disposal of Long-Lived
Assets Subsections of Subtopic 360-10. Estimates of those
effects shall be consistent with estimates of a market
participant. Generally, an entity shall consider all
available information including current prices, historical
averages, and forward pricing curves. Those marketplace
assumptions typically shall be consistent with an entity’s
operating plans and financial projections underlying other
aspects of the impairment analysis (for example, amount and
timing of production). It generally would be inappropriate
for an entity to use a single factor, such as the current
price or a historical average, as a surrogate for estimating
future prices without considering other information that a
market participant would consider.
An entity may determine that there is substantial doubt
about its ability to continue as a going concern and, therefore, that it
must test its long-lived assets for recoverability. Provided that its
financial statements continue to be presented on a going-concern basis
(i.e., not on a liquidation basis of accounting), the cash flow estimates
the entity uses for recoverability testing may extend beyond one year on the
basis of the remaining useful life of the primary asset (see Section 2.4.4).
However, an entity should ensure that its cash flow estimates are reasonable
given the circumstances. In addition, if there is substantial doubt about an
entity's ability to continue as a going concern, it is more likely that the
entity is considering alternative courses of action and, therefore, that use
of a probability-weighted approach to estimate cash flows may be warranted
(see Section
2.4.3).
An entity in bankruptcy may use projections from its
reorganization plan to determine future cash flows provided that (1) the
reorganization has been confirmed by the bankruptcy court or (2) management
(following the advice of counsel) believes that the reorganization will be
approved by the bankruptcy court. The cash flow estimates the entity uses
for recoverability testing may extend beyond the expected bankruptcy filing
and emergence date provided that the entity can support the estimates upon
emergence from bankruptcy. However, an entity should carefully consider the
factors that led it to file for bankruptcy and should ensure that any
forecasts beyond the emergence date are reasonable given the circumstances.
In addition, the entity may want to use a probability-weighted approach to
estimate cash flows (see Section 2.4.3), possibly factoring in a sale of assets if
the entity were not to obtain the needed financing or emerge from
bankruptcy.
2.4.1.4 Cash Flows for Interest Charges
ASC 360-10-35-29 clarifies that the estimates of future cash flows should
“exclude interest charges that will be recognized as an expense when
incurred” to ensure that two entities with essentially the same assets
(asset groups) and cash flows do not have different assessments of
recoverability as a result of differences in their capital structures.
Therefore, interest changes should not be included in the cash flows when
the assets are in use (see Section
2.4.5) but capitalized interest should be included when
assets are under development (see Section
2.4.6). (Also see Section
2.3.3 for a discussion of debt in asset groups.)
2.4.1.5 Cash Flows From Hedging Instruments
On the basis of the guidance in ASC 815-30-35-42, we believe that an entity
should exclude the expected cash flows of a derivative hedging instrument
from the estimates of future cash flows when testing an asset group for
recoverability. (However, entities with oil- and gas-producing activities
that apply the full cost method of accounting should consider the guidance
in ASC 932-360-S99-2.) ASC 815-30-35-42 states:
Existing requirements in generally accepted accounting principles
(GAAP) for assessing asset impairment or credit losses or
recognizing an increased obligation apply to an asset or liability
that gives rise to variable cash flows (such as a variable-rate
financial instrument) for which the variable cash flows (the
forecasted transactions) have been designated as being hedged and
accounted for pursuant to paragraphs 815-30-35-3 and 815-30-35-38
through 35-41. Those impairment or credit loss requirements shall be
applied each period after hedge accounting has been applied for the
period, pursuant to those paragraphs. The fair value or expected
cash flows of a hedging instrument shall not be considered in
applying those requirements. The gain or loss on the hedging
instrument in accumulated other comprehensive income shall, however,
be accounted for as discussed in paragraphs 815-30-35-38 through
35-41.
2.4.1.6 Cash Flows From Insurance Recoveries
ASC 360-10-35-29 states that “[e]stimates of future cash
flows used to test the recoverability of a long-lived asset (asset group)
shall include only the future cash flows (cash inflows less associated cash
outflows) that are directly associated with and that are expected to arise
as a direct result of the use and eventual disposition of the asset (asset
group).” Accordingly, we do not believe that an entity should include cash
inflows from an insurance recovery related to the damage or destruction of a
long-lived asset in its cash flow estimates for an asset group, since such
cash inflows do not arise as a direct result of the use and eventual
disposition of the asset. Rather, we believe that the entity should apply
the principles in ASC 360 to recognize any impairment loss for the
long-lived asset separately from any insurance recovery. Therefore,
expenditures needed to repair or replace the existing asset (if the same
service potential is assumed) should be included in the entity’s cash flow
estimates.
By contrast, some entities obtain business interruption insurance, which is
insurance coverage that reimburses an entity’s operating cash flows if it
cannot operate (or can operate only at a reduced capacity) because of a
covered loss. We believe that it is appropriate to include the cash flows
related to business interruption insurance in the cash flow estimates used
to test an asset group for recoverability.
The accounting framework underlying the insurance recovery model is based on
an analogy to the guidance in ASC 410 on recognition of potential loss
recoveries. Specifically, ASC 410-30-35-8, which provides
subsequent-measurement guidance related to environmental obligations,
states, in part:
Potential recoveries may be claimed from a number of
different parties or sources, including insurers, potentially
responsible parties other than participating potentially responsible
parties (see paragraph 410-30- 30-2), and governmental or
third-party funds. The amount of an environmental remediation
liability should be determined independently from any potential
claim for recovery, and an asset relating to the recovery shall be
recognized only when realization of the claim for recovery is deemed
probable. The term probable is used in this Subtopic with the
specific technical meaning in paragraph 450-20-25-1 [the future
event or events are likely to occur].
The recognition criteria for a loss recovery differ from those for a gain contingency. Provided that its collection is probable, a loss recovery is recognized in the period in which the loss is incurred (or the period in which collection becomes probable). By contrast, a gain contingency is recognized when it is realized or when it is realizable, whichever is earlier. While not codified, paragraph 16 of EITF Issue 01-10 discusses the
EITF’s understanding of the distinction between a loss recovery and a gain
contingency: a loss recovery represents the recovery of a loss already
recognized in the financial statements, whereas a gain contingency
represents the recovery of a loss not yet recognized in the financial
statements or recovery of an amount that is greater than the loss recognized
in the financial statements. Thus, a loss recovery may only be recognized up
to the amount of the loss incurred for an insurance recovery. Similarly, for
business interruption insurance, we do not believe that it would be
appropriate to recognize an amount in excess of the recovery of costs. Any
excess would be recognized as a gain contingency in income when realized or
realizable.
2.4.2 Cash Flow Estimates Based on Facts and Circumstances That Exist as of the Testing Date
Estimates of future cash flows used to test recoverability of an
asset group should take into account the facts and circumstances that exist as
of the testing date. For example, assume that an entity concludes that it has a
triggering event as of its fiscal year-end and performs a recoverability test as
of that date in the subsequent period. While performing the test and while
having no intention of disposing of the asset group, the entity receives and
accepts an unsolicited offer for the asset group. In performing the required
recoverability test on a held-and-used basis, since the entity had no intention
of disposing of the asset group as of the testing date, it should not assume
that the asset group would be sold (or use a probability-weighted approach and
include a sale as one of the scenarios) (see the next section).
2.4.3 Probability-Weighted and Best-Estimate Cash Flow Approaches
Entities are permitted to use either a best-estimate approach or
a probability-weighted approach to estimating future cash flows. ASC
360-10-35-30 states, in part:
However, if alternative
courses of action to recover the carrying amount of a long-lived asset
(asset group) are under consideration or if a range is estimated for the
amount of possible future cash flows associated with the likely course of
action, the likelihood of those possible outcomes shall be considered. A
probability-weighted approach may be useful in considering the likelihood of
those possible outcomes.
An entity often uses a best-estimate approach when (1)
operations are stable and (2) the entity is not considering alternative courses
of action to recover an asset. However, when operations are not stable and there
is a range of possible future cash flows or the entity is considering
alternatives, such as potentially selling or abandoning an asset group versus
continuing to use it, entities typically use a probability-weighted approach to
comply with ASC 360-10-35-30. Specifically, ASC 360-10-35-30 states that if
alternative courses of action are under consideration, “the likelihood of those
possible outcomes shall be considered.” An entity is not precluded from using
different approaches for different asset groups if management is considering
different alternatives for one asset group but not for others.
One of the impairment indicators in ASC 360-10-35-21 is “[a]
current expectation that, more likely than not, a long-lived asset (asset group)
will be sold or otherwise disposed of significantly before the end of its
previously estimated useful life. The term more likely than not refers to a
level of likelihood that is more than 50 percent.” Therefore, entities may need
to perform a recoverability test when they are considering selling an asset
group but have not yet met the held-for-sale classification criteria. ASC
360-10-55-23 through 55-29 contain an example illustrating the
probability-weighted approach for developing estimates of future cash flows when
an entity is considering selling an asset group.
ASC 360-10
Example 2:
Probability-Weighted Cash Flows
55-23 This
Example illustrates the use of a probability-weighted
approach for developing estimates of future cash flows
used to test a long-lived asset for recoverability when
alternative courses of action are under consideration
(see paragraph 360-10-35-30). This Example has the
following Cases:
- Probability-weighted cash flows (Case A)
- Expected cash flows technique (Case B).
55-24 Cases A
and B share all of the following assumptions.
55-25 As of
December 31, 20X2, a manufacturing facility with a
carrying amount of $48 million is tested for
recoverability. At that date, 2 courses of action to
recover the carrying amount of the facility are under
consideration — sell in 2 years or sell in 10 years (at
the end of its remaining useful life).
55-26 The
possible cash flows associated with each of those
courses of action are $41 million and $48.7 million,
respectively. They are developed based on
entity-specific assumptions about future sales (volume
and price) and costs in varying scenarios that consider
the likelihood that existing customer relationships will
continue, changes in economic (market) conditions, and
other relevant factors.
Case A: Probability-Weighted Cash
Flows
55-27 The
following table shows the possible cash flows associated
with each of the courses of action — sell in 2 years or
sell in 10 years.
55-28 As
further indicated in the following table, there is a 60
percent probability that the facility will be sold in 2
years and a 40 percent probability that the facility
will be sold in 10 years.
55-29 The
alternatives of whether to sell or use an asset are not
necessarily independent of each other. In many
situations, after estimating the possible future cash
flows relating to those potential courses of action, an
entity might select the course of action that results in
a significantly higher estimate of possible future cash
flows. In that situation, the entity generally would use
the estimates of possible future cash flows relating
only to that course of action in computing future cash
flows. As shown, the expected cash flows are $44.1
million (undiscounted). Therefore, the carrying amount
of the facility of $48 million would not be
recoverable.
Case B: Expected Cash Flows Technique
55-30 This
Case illustrates the application of an expected present
value technique to estimate the fair value of a
long-lived asset in an impairment situation.
55-31 The
following table shows by year the computation of the
expected cash flows used in the measurement. They
reflect the possible cash flows (probability-weighted)
used to test the manufacturing facility for
recoverability in Case A, adjusted for relevant
marketplace assumptions, which increases the possible
cash flows in total by approximately 15 percent.
55-32 The
following table shows the computation of the expected
present value; that is, the sum of the present values of
the expected cash flows by year, each discounted at a
risk-free interest rate determined from the yield curve
for U.S. Treasury instruments. In this Case, a market
risk premium is included in the expected cash flows;
that is, the cash flows are certainty equivalent cash
flows. As shown, the expected present value is $42.3
million, which is less than the carrying amount of $48
million. In accordance with paragraph 360-10-35-17 the
entity would recognize an impairment loss of $5.7
million.
2.4.4 Primary Asset and the Cash Flow Estimation Period
ASC 360-10
35-31
Estimates of future cash flows used to test the
recoverability of a long-lived asset (asset group) shall
be made for the remaining useful life of the asset
(asset group) to the entity. The remaining useful life
of an asset group shall be based on the remaining useful
life of the primary asset of the group. For purposes of
this Subtopic, the primary asset is the principal
long-lived tangible asset being depreciated or
intangible asset being amortized that is the most
significant component asset from which the asset group
derives its cash-flow-generating capacity. The primary
asset of an asset group therefore cannot be land or an
intangible asset not being amortized.
35-32 Factors
that an entity generally shall consider in determining
whether a long-lived asset is the primary asset of an
asset group include the following:
- Whether other assets of the group would have been acquired by the entity without the asset
- The level of investment that would be required to replace the asset
- The remaining useful life of the asset relative to other assets of the group. If the primary asset is not the asset of the group with the longest remaining useful life, estimates of future cash flows for the group shall assume the sale of the group at the end of the remaining useful life of the primary asset.
The period over which an entity should estimate cash flows when
performing the recoverability test for a single long-lived asset should
correspond to the asset’s remaining useful life to the entity. When long-lived
assets with different remaining useful lives are grouped together to form an
asset group, the cash flow estimation period for the group is based on the
remaining useful life of the primary asset of the group to the entity.
The primary asset is “the principal long-lived tangible asset
being depreciated or intangible asset being amortized that is the most
significant component asset from which the asset group derives its
cash-flow-generating capacity.” To prevent an entity from estimating cash flows
over an unlimited period, the primary asset must be an asset with a finite
useful life and therefore cannot be land, goodwill, an indefinite-lived
intangible asset, or an internally generated intangible asset that has been
expensed as incurred.
The primary asset is typically the asset in the asset group that
has the longest remaining useful life to the entity, would require the highest
level of investment to replace, and without which some or all of the other
assets of the group might not have continuing service potential. The primary
asset is not always the asset with the longest remaining useful life. ASC
360-10-35-32(c) states that if the primary asset is not the asset that has the
longest remaining useful life, estimates of future cash flows for the group
should be based on the assumption that the group will be sold “at the end of the
remaining useful life of the primary asset.” In some cases, identifying the
primary asset is relatively straightforward, but in other cases it may be
challenging, especially when multiple long-lived assets appear crucial to
generating the cash flows of the asset group. Entities will therefore need to
apply judgment in such situations.
If the entity determines that it must change the depreciation or
amortization period for the primary asset, it must use the revised useful life
in developing its cash flow estimates. For example, if, concurrently with the
triggering event, the entity determines that it must shorten the useful life of
the primary asset from five years to three years, the undiscounted cash flows
should be determined for the revised useful life of the primary asset, which
would be three years. See Section 2.7 for more information.
2.4.5 Expenditures for Assets That Are in Use
ASC 360-10
35-33
Estimates of future cash flows used to test the
recoverability of a long-lived asset (asset group) that
is in use, including a long-lived asset (asset group)
for which development is substantially complete, shall
be based on the existing service potential of the asset
(asset group) at the date it is tested. The service
potential of a long-lived asset (asset group)
encompasses its remaining useful life,
cash-flow-generating capacity, and for tangible assets,
physical output capacity. Those estimates shall include
cash flows associated with future expenditures necessary
to maintain the existing service potential of a
long-lived asset (asset group), including those that
replace the service potential of component parts of a
long-lived asset (for example, the roof of a building)
and component assets other than the primary asset of an
asset group. Those estimates shall exclude cash flows
associated with future capital expenditures that would
increase the service potential of a long-lived asset
(asset group).
ASC 360-10 requires that the cash flows used in the
recoverability test for an asset group that is in use (including an asset group
for which development is substantially complete) be based on the existing
service potential of an asset group as of the date on which it is tested.
According to paragraph B29 of the Background Information and Basis for Conclusions of FASB Statement 144, “estimates of future cash flows
used to test recoverability should include cash flows (including estimated
salvage values) associated with asset-related expenditures that replace (a)
component parts of a long-lived asset or (b) component assets (other than the
primary asset) of an asset group, whether those expenditures would be recognized
as an expense or capitalized in future periods.” However, paragraph B28 states
that such estimates should exclude “the cash flows associated with asset-related
expenditures that would enhance the existing service potential of a long-lived
asset (asset group) that is in use.” Cash flow estimates should be based on the
existing service potential of the asset group and therefore should include cash
flows associated with future expenditures (e.g., repairs and maintenance and
replacements) necessary to maintain the service potential of the asset group.
Accordingly, if the entity’s budgets and forecasts assume major capital
improvements or expansion rather than maintenance and capital replacements, an
entity should exclude the capital improvements or expansions from its cash flows
estimates in assessing impairment.
Connecting the Dots
ASC 360-10 provides no guidance on determining at what
point a long-lived asset (asset group) in development is “substantially
complete.” We believe that, in such circumstances, an entity should look
to the guidance in ASC 835-20-25-5, which states:
The capitalization period shall end when the asset is substantially
complete and ready for its intended use. Consider the capitalization
period that is appropriate in each of the following examples:
- Some assets are completed in parts, and each part is capable of being used independently while work is continuing on other parts. An example is a condominium. For such assets, interest capitalization shall stop on each part when it is substantially complete and ready for use.
- Some assets must be completed in their entirety before any part of the asset can be used. An example is a facility designed to manufacture products by sequential processes. For such assets, interest capitalization shall continue until the entire asset is substantially complete and ready for use.
- Some assets cannot be used effectively until a separate facility has been completed. Examples are the oil wells drilled in Alaska before completion of the pipeline. For such assets, interest capitalization shall continue until the separate facility is substantially complete and ready for use.
ASC 835-20-26-6 also states that an asset may be
considered substantially complete when the “completion of the asset is
intentionally delayed.”
2.4.6 Expenditures for Assets That Are Under Development
ASC 360-10
35-34
Estimates of future cash flows used to test the
recoverability of a long-lived asset (asset group) that
is under development shall be based on the expected
service potential of the asset (group) when development
is substantially complete. Those estimates shall include
cash flows associated with all future expenditures
necessary to develop a long-lived asset (asset group),
including interest payments that will be capitalized as
part of the cost of the asset (asset group). Subtopic
835-20 requires the capitalization period to end when
the asset is substantially complete and ready for its
intended use.
35-35 If a
long-lived asset that is under development is part of an
asset group that is in use, estimates of future cash
flows used to test the recoverability of that group
shall include the cash flows associated with future
expenditures necessary to maintain the existing service
potential of the group (see paragraph 360-10-35-33) as
well as the cash flows associated with all future
expenditures necessary to substantially complete the
asset that is under development (see the preceding
paragraph). See Example 3 (paragraph 360-10-55-33). See
also paragraphs 360-10-55-7 through 55-18 for
considerations of site restoration and environmental
exit costs.
Paragraph B31 of the Background Information and Basis for Conclusions of FASB Statement 144 states, in part:
The
Board observed that in contrast to a long-lived asset (asset group) that is
in use, a long-lived asset (asset group) that is under development will not
provide service potential until development is substantially complete. The
Board decided that such an asset (asset group) should be tested for
recoverability based on its expected service potential.
Therefore, ASC 360-10-35-35 requires that estimates of future
cash flows used in the recoverability test include the cash flows (cash outflows
and cash inflows) associated with all future asset-related expenditures
necessary to develop the asset group, regardless of whether those expenditures
would be recognized as an expense or capitalized in future periods.
While ASC 360-10-35-29 requires that cash flow estimates used in a recoverability test exclude interest payments that will be recognized as an expense when incurred, the cash flow estimates for asset groups under development should include interest payments that will be capitalized in accordance with ASC 835-20 as part of the cost of the assets in the group. Paragraph B32 of the Background Information and Basis for Conclusions of FASB Statement 144 states, in part:
The Board reasoned that for
a long-lived asset (asset group) that is under development, there is no
difference between interest payments and other asset-related expenditures
that would be capitalized in future periods. Therefore, the Board decided
that estimates of future cash flows used to test a long-lived asset (asset
group) for recoverability should exclude only those interest payments that
would be recognized as an expense when incurred.
Further, ASC 360-10-35-35 states that “[i]f a long-lived asset
that is under development is part of an asset group that is in use, estimates of
future cash flows used to test the recoverability of that group shall include”
future asset-related expenditures needed to (1) “substantially complete the
asset that is under development” and (2) maintain the existing service potential
of the other assets that are in use. ASC 360-10 includes an example illustrating
this concept.
ASC 360-10
Example 3: Estimates of Future Cash
Flows Used to Test an Asset Group for Recoverability
55-33 A
long-lived asset that is under development may be part
of an asset group that is in use. In that situation,
estimates of future cash flows used to test the
recoverability of that group shall include the cash
flows associated with future expenditures necessary to
maintain the existing service potential of the group as
well as the cash flows associated with future
expenditures necessary to substantially complete the
asset that is under development (see paragraph
360-10-35-35).
55-34 An
entity engaged in mining and selling phosphate estimates
future cash flows from its commercially minable
phosphate deposits in order to test the recoverability
of the asset group that includes the mine and related
long-lived assets (plant and equipment). Deposits from
the mined rock must be processed in order to extract the
phosphate. As the active mining area expands along the
geological structure of the mine, a new processing plant
is constructed near the production area. Depending on
the size of the mine, extracting the minable deposits
may require building numerous processing plants over the
life of the mine. In testing the recoverability of the
mine and related long-lived assets, the estimates of
future cash flows from its commercially minable
phosphate deposits would include cash flows associated
with future expenditures necessary to build all of the
required processing plants.
Example 2-2
Entity D designs, develops, and
manufactures components for high-speed optical networks.
The majority of D’s customers are building communication
infrastructures. In December 20X1, D purchased a plot of
land in an industrial complex, intending to build a
state-of-the-art production facility for D’s integrated
circuit and module products. Construction of the new
facility began in March 20X2 and is expected to be
completed by the end of August 20X2. In June 20X2, a
number of D’s customers announced plans to cut the level
of capital expenditures related to their infrastructure
buildout and D has received several order cancellations.
As of June 30, 20X2, because of the significant change
in business climate, D has determined that it is
required to assess the recoverability of the new
production facility in accordance with ASC
360-10-35-21(c).
ASC 360-10-35-34 requires that estimates
of future cash flows for the partially completed
production facility include all cash outflows associated
with the completion of the facility, including any
interest payments that would be capitalized as part of
the facility. Therefore, D should include the remaining
costs associated with completing the production facility
in its estimates of future cash flows when assessing the
asset group for recoverability. In addition, D will need
to include any payments to maintain the existing service
potential related to the facility once it is open for
production. Entity D’s estimates of future cash flows
used to test the recoverability of the facility should
be based on its expected useful life.
2.4.7 Certain Site Restoration and Environmental Exit Costs
ASC 360-10-55 provides detailed guidance on how an entity should
treat site restoration and environmental exit costs when testing an asset group
for recoverability. It lists indicators for when the cash flows for
environmental exit costs would or would not be included in the cash flows used
for recoverability testing.
ASC 360-10
Treatment of Certain Site
Restoration and Environmental Exit Costs When
Testing a Long-Lived Asset for Impairment
55-1 The
following guidance demonstrates the consideration of
restoration and environmental exit costs when testing a
long-lived asset for impairment. Paragraphs 360-10-35-18
through 35-19 also provide guidance for such testing for
assets subject to asset retirement obligations.
55-2 For
certain assets covered by this Subtopic, costs for
future site restoration or closure (environmental exit
costs) may be incurred if the asset is sold, is
abandoned, or ceases operations. Environmental exit
costs within the scope of this Subsection include:
- Asset retirement costs recognized pursuant to Subtopic 410-20
- Asset retirement costs that have not been recognized because the obligation has not been incurred
- Certain environmental remediation costs that have not yet been recognized as a liability pursuant to Subtopic 410-30.
55-3 Pursuant
to Subtopic 410-20, asset retirement costs may be
incurred over more than one reporting period. For
example, the liability for performing certain capping,
closure, and postclosure activities in connection with
operating a landfill is incurred as the landfill
receives waste.
55-4 The
related cash flows, if any, might not occur until the
end of the asset’s life if the asset ceases operations,
or they might be deferred indefinitely as long as the
asset is not sold or abandoned.
55-5 The
issue is whether the cash flows associated with
environmental exit costs that may be incurred if a
long-lived asset is sold, is abandoned, or ceases
operations should be included in the undiscounted
expected future cash flows used to test a long-lived
asset for recoverability under this Subtopic.
55-6 For environmental exit
costs that have not been recognized as a liability for
accounting purposes, whether those environmental exit
costs shall be included in the undiscounted expected
future cash flows used to test a long-lived asset for
recoverability under this Subtopic depends on
management’s intent with respect to the asset. Pursuant
to this Subtopic, if management’s intent contemplates
alternative courses of action to recover the carrying
amount of the asset or if a range is estimated for the
amount of possible future cash flows, the likelihood of
those possible outcomes shall be considered. Examples of
management’s intent and the corresponding treatment of
the environmental exit costs in this Subtopic’s
recoverability test are described below. (Environmental
remediation costs discussed in certain of these cases
refer to environmental remediation costs that have not
yet been recognized as a liability pursuant to Subtopic
410-30.) This paragraph illustrates the guidance in
paragraphs 360-10-35-29 through 35-35 on estimating
future cash flows used to test a long-lived asset for
recoverability.
Environmental Exit Costs That Shall Be Excluded
From This Subtopic’s Recoverability Test
55-7 The
following guidance demonstrates the consideration of
restoration and environmental exit costs when testing a
long-lived asset for impairment. In all of the following
situations, environmental exit costs would be excluded
from this Subtopic’s recoverability test.
Management Intends to Operate Asset, Future Cash Flows
Exceed Carrying Amount, and No Expectation of Cash
Outflow in Disposition
55-8
Management intends to operate the asset for at least the
asset’s remaining depreciable life, the sum of the
undiscounted future cash flows expected from the asset’s
use during that period exceeds the asset’s carrying
amount including any associated goodwill, and management
has no reason to believe that the asset’s eventual
disposition will result in a net cash outflow.
Management Expects to Operate Asset, Asset Generating
Positive Cash Flows, Profitability Expected to Continue,
and No Constraints on Economic Life
55-9
Management expects to operate the asset indefinitely and
has the ability to do so, the asset is generating
positive cash flows, management’s best information
indicates that the asset will continue to be profitable
in the future, and there are no known constraints to the
asset’s economic life. This Subtopic’s recoverability
test shall include the future cash outflows for repairs,
maintenance, and capital expenditures necessary to
obtain the future cash inflows expected to be generated
by the asset based on its existing service potential.
Asset Has Finite Life but Remediation Costs Only Incurred
if Asset Sold or Abandoned
55-10 The
asset has a finite economic life, but environmental
remediation costs will only be incurred if the asset is
sold or abandoned. At the end of the asset’s life,
management intends either to close the asset permanently
because the costs of remediating the asset exceed the
proceeds that likely would be received if the asset were
sold or, alternatively, to idle the asset by reducing
production to a minimal or nominal amount. (Although the
environmental remediation costs are excluded from this
Subtopic’s recoverability test, the recoverability test
shall incorporate the entity’s own assumptions about its
use of the asset. That is, the recoverability test shall
consider the likelihood of the alternative courses of
action [either closing or idling the asset] and the
resulting cash flows associated with those alternative
courses.)
Management Expects to Sell Asset and Remediation Costs
Not Required
55-11
Management expects to sell the asset in the future, and
the asset’s sale will not require the environmental
remediation costs to be incurred. (Although the
environmental remediation costs are excluded from this
Subtopic’s recoverability test, the fair value of the
asset is likely to be affected by the existence of those
costs. The diminished fair value shall be considered in
estimating the cash flows expected to arise from the
eventual sale of the asset.)
Environmental Exit Costs That Shall Be Included in
This Subtopic’s Recoverability Test
55-12 The
following guidance demonstrates the consideration of
restoration and environmental exit costs when testing a
long-lived asset for impairment. In all of the following
situations, environmental exit costs would be included
in this Subtopic’s recoverability test.
Management Expects Remediation Costs to Be Incurred but
Uncertainties Exist in Application of Laws
55-13
Management expects to take a future action related to
the asset that may cause the environmental remediation
costs to be incurred. However, uncertainties or
inconsistencies exist in how the related laws or
regulatory requirements are applied. Management
estimates, based on the weight of the available
evidence, a 60 percent chance that the remediation costs
will not be incurred and a 40 percent chance that those
costs will be incurred. Pursuant to this Subtopic, other
situations may exist in which cash flows are estimated
using a single set or best estimate of cash flows.
Useful Life Limited and Then Asset Disposition Required
55-14 The
useful life of the asset is limited as a result of any
of the following:
- Actual or expected technological advances
- Contractual provisions
- Regulatory restrictions.
Also, when the asset’s service potential has ended,
management will be required to dispose of the asset
under paragraph 360-10-55-16 or 360-10-55-17.
Continuing Losses May Require Asset Disposition
55-15 The
asset has a current period cash flow loss from
operations combined with a projection or forecast that
anticipates continuing losses. Management expects the
asset to achieve profitability in the future but
uncertainty exists about management’s ability to fund
the future cash outflows up to the time that net cash
inflows are expected from the asset’s use. In the event
of a forced liquidation, management would likely dispose
of the asset under the following paragraph or paragraph
360-10-55-17.
Intent to Abandon or Close an Asset
55-16
Management intends to abandon or close the asset in the
future, and the event of abandonment or closure will
cause the environmental remediation costs to be
incurred.
Future Sale Will Require Remediation Costs to Be Incurred
55-17
Management intends to sell the asset in the future, and
the applicable laws, regulations, or interpretations
thereof require that appropriate environmental
remediation (not within the scope of Subtopic 410-20)
occur in connection with the sale.
Management Expects to Operate Asset and Retirement Costs
to Be Incurred Over Its Life
55-18
Management expects to operate the asset for the
remainder of its useful life. Related asset retirement
costs are incurred over the life of the asset (for
example, the operation of a landfill). Estimated cash
flows associated with the asset retirement costs yet to
be incurred and recognized shall be included in this
Subtopic’s recoverability test.
For more information about the accounting for environmental
obligations, see Deloitte’s Roadmap Environmental Obligations and Asset Retirement
Obligations.
2.4.8 Assets Subject to Asset Retirement Obligations
ASC 360-10
35-18 In
applying the provisions of this Subtopic, the carrying
amount of the asset being tested for impairment shall
include amounts of capitalized asset retirement costs.
Estimated future cash flows related to the liability for
an asset retirement obligation that has been recognized
in the financial statements shall be excluded from both
of the following:
- The undiscounted cash flows used to test the asset for recoverability
- The discounted cash flows used to measure the asset’s fair value.
35-19 If the
fair value of the asset is based on a quoted market
price and that price considers the costs that will be
incurred in retiring that asset, the quoted market price
shall be increased by the fair value of the asset
retirement obligation for purposes of measuring
impairment.
The initial liability for an asset retirement obligation is
recognized, and a corresponding amount is added to the carrying amount of the
related long-lived asset. The liability is adjusted in each period to reflect
the passage of time (i.e., accretion expense) and any changes in the estimated
future cash flows underlying the initial fair value measurement.
ASC 360-10-35-18 requires that “the carrying amount of the asset
being tested for impairment . . . include amounts of capitalized asset
retirement costs.” However, the asset retirement obligation liability should be
excluded from the asset group. Accordingly, the estimates of future cash
outflows associated with the asset retirement obligation liability should also
be excluded from the impairment test. In addition, ASC 360-10 requires that an
adjustment (an increase) be made to the fair value of the asset group if that
fair value takes into account the costs that will be incurred in retiring that
asset.
For more information about the accounting for asset retirement
obligations, see Deloitte’s Roadmap Environmental Obligations and Asset Retirement
Obligations.
2.5 Measurement of an Impairment Loss
ASC 360-10
Measurement of an Impairment Loss
35-17
An impairment loss shall be recognized only if the carrying
amount of a long-lived asset (asset group) is not
recoverable and exceeds its fair value. The carrying amount
of a long-lived asset (asset group) is not recoverable if it
exceeds the sum of the undiscounted cash flows expected to
result from the use and eventual disposition of the asset
(asset group). That assessment shall be based on the
carrying amount of the asset (asset group) at the date it is
tested for recoverability, whether in use (see paragraph
360-10-35-33) or under development (see paragraph
360-10-35-34). An impairment loss shall be measured as the
amount by which the carrying amount of a long-lived asset
(asset group) exceeds its fair value.
ASC 360-10 defines impairment as “the condition that exists when the carrying amount
of a long-lived asset (asset group) exceeds its fair value.” When an entity
determines that the carrying amount of the asset group is not recoverable because
the undiscounted cash flows used in the recoverability test are less than its
carrying amount, an impairment loss is measured as the amount by which the carrying
amount exceeds fair value. An impairment loss is allocated to the long-lived assets
within the scope of ASC 360-10 “on a pro rata basis using the relative carrying
amounts of those assets, except that the loss allocated to an individual long-lived
asset of the group shall not reduce the carrying amount of that asset below its fair
value whenever that fair value is determinable without undue cost and effort.”
Bridging the GAAP
Under IAS 36, if impairment indicators exist, an entity
applies a one-step approach in calculating a CGU impairment. That is, the
amount by which the carrying value of the asset or CGU exceeds the
recoverable amount is recorded as an impairment loss. The recoverable amount
for impairment (whether property, plant, and equipment [PP&E];
intangibles; or goodwill) is defined as the greater of:
- The asset’s or CGU’s fair value less costs to sell.
- The sum of future discounted cash flows, including the disposal value (also referred to as the value in use).
2.5.1 Determining the Fair Value of an Asset Group
ASC 360-10
35-36 For
long-lived assets (asset groups) that have uncertainties
both in timing and amount, an expected present value
technique will often be the appropriate technique with
which to estimate fair value.
The fair value of an asset group and the individual assets is
measured in accordance with ASC 820, which establishes a framework for measuring
fair value and requires disclosures about fair value measurements. Below is a
brief overview of the principles of ASC 820. For detailed information about
measuring fair value, see Deloitte’s Roadmap Fair Value Measurements and Disclosures (Including
the Fair Value Option).
2.5.1.1 Exit Price
ASC 820-10-20 defines fair value as the “price that would be received to sell
an asset or paid to transfer a liability in an orderly transaction between
market participants at the measurement date.” Thus, a fair value measurement
is an “exit price.” The exit price for an asset or liability conceptually
differs from its transaction price, which is an entry price. While an exit
price and an entry price could be the same in many situations, a transaction
price cannot be presumed to represent the fair value of an asset or
liability.
2.5.1.2 Unit of Valuation Versus Unit of Account
The unit of valuation is the grouping of assets, liabilities, or equity
instruments for fair value measurement purposes. ASC 820 provides guidance
on determining the unit of valuation. The unit of valuation (also referred
to as the “valuation premise”) for nonfinancial assets is the asset’s
highest and best use. The highest and best use of an asset might provide
maximum value through its use either (1) in combination with other assets or
other assets and liabilities or (2) on a stand-alone basis.
The unit of account represents the level of aggregation or disaggregation of
individual assets, liabilities, or equity instruments for recognition in the
financial statements and is generally determined on the basis of the
guidance in the Codification topics. Under ASC 360-10, the unit of account
for impairment testing is the asset group (or the disposal group when assets
are held for sale). However, the asset group is not the unit of account for
recognition purposes when the assets are held and used (but is the unit of
account when the disposal group is held for sale). Rather, each of the
individual long-lived assets represents a single unit of account. Therefore,
in accordance with ASC 360-10-35-28, an entity must allocate the difference
between the fair value of the asset group and the carrying amount of the
asset group (i.e., the amount of impairment) to individual long-lived assets
within the asset group. This allocation is required even if the unit of
valuation for fair value measurement purposes is the asset group.
While the unit of account may differ conceptually from the unit of valuation,
the unit of account for testing the impairment of the asset group generally
will be the same as the unit of valuation. If the entity determines that the
unit of valuation should differ from the asset group (i.e., the highest and
best use of an asset group would be to group it together with other assets
and, possibly, liabilities), it should reconsider whether it has properly
identified its asset groups.
2.5.1.3 Highest and Best Use
When determining the fair value of an asset group, an entity must consider
the highest and best use of the nonfinancial asset(s) from a
market-participant perspective. ASC 820-10-35-10C states that the “[h]ighest
and best use is determined from the perspective of market participants, even
if the reporting entity intends a different use,” but clarifies that “a
reporting entity’s current use of a nonfinancial asset is presumed to be its
highest and best use unless market or other factors suggest that a different
use by market participants would maximize the value of the asset.”
2.5.1.4 Market Participants
To meet the fair value measurement objective in ASC 820, an entity must
develop assumptions that market participants would use to determine the
price of an asset, liability, or equity instrument in an orderly transaction
as of the measurement date. ASC 820 defines the term “market participants”
as follows:
Buyers and sellers in the principal (or most advantageous)
market for the asset or liability that have all of the following
characteristics:
- They are independent of each other, that is, they are not related parties, although the price in a related-party transaction may be used as an input to a fair value measurement if the reporting entity has evidence that the transaction was entered into at market terms.
- They are knowledgeable, having a reasonable understanding about the asset or liability and the transaction using all available information, including information that might be obtained through due diligence efforts that are usual and customary.
- They are able to enter into a transaction for the asset or liability.
- They are willing to enter into a transaction for the asset or liability, that is, they are motivated but not forced or otherwise compelled to do so.
2.5.1.5 Principal (or Most Advantageous) Market
Underlying the fair value measurement objective in ASC 820
is the concept of an entity transacting in the principal market for the
asset or liability (or equity instrument), or in the absence of a principal
market, the most advantageous market. The ASC master glossary defines the
principal market as the “market with the greatest volume and level of
activity for the asset or liability” and the most advantageous market as the
“market that maximizes the amount that would be received to sell the asset
or minimizes the amount that would be paid to transfer the liability, after
taking into account transaction costs and transportation costs.” The
determination of the principal (or most advantageous) market for an asset,
liability, or equity instrument can affect the fair value measurement since
the exit price may differ from market to market. The concept of the most
advantageous market is relevant only if there is no principal market for the
asset, liability, or equity instrument subject to the fair value
measurement.
2.5.1.6 Valuation Techniques
An entity measures fair value on the basis of one or more of the three
valuation approaches outlined in ASC 820-10-35-24A: (1) the market approach,
(2) the income approach, or (3) the cost approach. Further, ASC 820-10-35-24
notes that the entity selects one or more techniques “that are appropriate
in the circumstances and for which sufficient data are available” to
maximize the use of observable inputs while minimizing the use of
unobservable inputs. If multiple techniques are used, the entity should
evaluate the resultant range and should select a point within the range that
is most representative of fair value.
2.5.2 Assets Subject to Nonrecourse Debt
Long-lived assets may include property subject to nonrecourse debt. The fair value of the property should be determined without regard to the nonrecourse provisions. If the carrying amount of the property that reverts back to the lender is less than the amount of nonrecourse debt extinguished, a gain would be recognized on extinguishment. Paragraph B34 of the Background Information and Basis for Conclusions of FASB Statement 144 describes the Board’s rationale for
requiring such recognition:
The recognition of an impairment loss and the
recognition of a gain on the extinguishment of debt are separate events, and
each event should be recognized in the period in which it occurs. The Board
believes that the recognition of an impairment loss should be based on the
measurement of the asset at its fair value and that the existence of
nonrecourse debt should not influence that measurement.
2.5.3 Allocating an Impairment Loss to the Assets in the Asset Group
ASC 360-10
35-28 An impairment loss for
an asset group shall reduce only the carrying amounts of
a long-lived asset or assets of the group. The loss
shall be allocated to the long-lived assets of the group
on a pro rata basis using the relative carrying amounts
of those assets, except that the loss allocated to an
individual long-lived asset of the group shall not
reduce the carrying amount of that asset below its fair
value whenever that fair value is determinable without
undue cost and effort. See Example 1 (paragraph
360-10-55-20) for an illustration of this guidance.
If the carrying amount of the asset group exceeds its fair
value, an impairment loss is recognized. If the impairment loss is related to an
individual long-lived asset, the asset should be reduced to its fair value. If
the impairment loss is determined for an asset group, the amount by which the
carrying amount exceeds fair value must be allocated to the long-lived assets
within the scope of ASC 360-10 “on a pro rata basis using the relative carrying
amounts of those assets, except that the loss allocated to an individual
long-lived asset of the group shall not reduce the carrying amount of that asset
below its fair value whenever that fair value is determinable without undue cost
and effort.” Therefore, the impairment loss should not be allocated to goodwill,
indefinite-lived intangibles, or other assets that are not within the scope of
ASC 360-10, even if those assets are included in the asset group being tested
for recoverability. In addition, entities should not reduce the carrying amount
of an individual asset below its fair value whenever the fair value is
determinable without undue cost and effort. We believe that since FASB Statement
144 was issued, entities have become more comfortable with fair value
measurements and that the fair value of most assets therefore should be
determinable without undue cost and effort.
If an entity determines that the fair value of one or more of the long-lived
assets in the asset group would exceed its adjusted amount if the impairment
were allocated to it, the entity should increase the adjusted carrying value for
that asset (or assets) to its fair value and allocate that excess to the other
long-lived assets in the group.
An outcome in which an entity cannot recognize the entire impairment loss because
it would result in recognition of one or more long-lived assets below fair value
is not expected. Accordingly, when such an outcome might be initially indicated,
we believe that the entity should revisit (1) the determination of the fair
value of the asset group, (2) the determination of the fair value of the
individual assets within the group when the impairment loss is allocated, and
(3) whether any other assets within the asset group that are not within the
scope of ASC 360-10 are impaired in accordance with ASC 360-10-35-27 (see
Section 2.3.7).
An entity must use the pro rata allocation approach prescribed
by ASC 360 for allocating an impairment loss. That is, the entity cannot pick
the long-lived assets to which it will allocate an impairment loss while not
allocating the loss to other assets. In some cases, the allocation approach
could cause the adjusted carrying amount of an asset to exceed the individual
asset’s fair value. An entity is not permitted to write that asset down to its
individual fair value and increase the carrying amounts of other long-lived
assets in the group.
Example 1 from ASC 360-10-55-20 through 55-22 illustrates the
allocation of an impairment loss to the long-lived assets within an asset
group.
ASC 360-10
Example 1: Allocation of Impairment
Loss
55-20 This Example
illustrates the allocation of an impairment loss to the
long-lived assets of an asset group (see paragraph
360-10-35-28).
55-21 An entity owns a
manufacturing facility that together with other assets
is tested for recoverability as a group. In addition to
long-lived assets (Assets A–D), the asset group includes
inventory measured using first-in, first-out (FIFO),
which is reported at the lower of cost and net
realizable value in accordance with Topic 330, and other
current assets and liabilities that are not covered by
this Subtopic. The $2.75 million aggregate carrying
amount of the asset group is not recoverable and exceeds
its fair value by $600,000. In accordance with paragraph
360-10-35-28, the impairment loss of $600,000 would be
allocated as shown below to the long-lived assets of the
group.
55-22 If the fair value of
an individual long-lived asset of an asset group is
determinable without undue cost and effort and exceeds
the adjusted carrying amount of that asset after an
impairment loss is allocated initially, the excess
impairment loss initially allocated to that asset would
be reallocated to the other long-lived assets of the
group. For example, if the fair value of Asset C is
$822,000, the excess impairment loss of $100,000
initially allocated to that asset (based on its adjusted
carrying amount of $722,000) would be reallocated as
shown below to the other long-lived assets of the group
on a pro rata basis using the relative adjusted carrying
amounts of those assets.
2.6 Adjusted Carrying Amount Becomes New Cost Basis
ASC 360-10
35-20
If an impairment loss is recognized, the adjusted carrying
amount of a long-lived asset shall be its new cost basis.
For a depreciable long-lived asset, the new cost basis shall
be depreciated (amortized) over the remaining useful life of
that asset. Restoration of a previously recognized
impairment loss is prohibited.
When an impairment loss is recognized, it is recognized as an adjustment to the cost
basis of the asset. Entities may not reverse impairment losses on assets classified
as held and used even if the value of the assets subsequently increases.
While the term “new cost basis” is not defined, we believe that it
suggests that any previously recognized accumulated depreciation or amortization should be eliminated against the carrying amount of the asset when an impairment loss is recognized for the asset. This is supported by paragraph B34 of the Background Information and Basis for Conclusions of FASB Statement 144, which notes
that “a decision to continue to use the impaired asset is equivalent to a new asset
purchase decision, and a new basis of fair value is appropriate.” Therefore, the new
cost basis of an asset is its cost basis just before the recognition of the
impairment loss less (1) the accumulated depreciation or amortization to date and
(2) the impairment loss allocated to the asset.
Example 2-3
Entity A, which has an asset with an
original cost of $250 and accumulated depreciation of $50,
recognizes an impairment loss of $25 for the asset. The new
cost basis of the asset after A recognizes the impairment
less is as follows:
However, in the absence of specific guidance, there may be diversity
in practice related to eliminating the previously recognized accumulated
depreciation or amortization.
Future depreciation or amortization of the asset is estimated
according to its new cost basis (less salvage value) and remaining useful life.
Future accumulated depreciation or amortization equals the depreciation or
amortization expense that will be recognized after the impairment.
However, for entities that are subject to cost-based regulation and apply ASC 980,
original historical cost is a key measure for determining regulated rates that may
be charged. Accordingly, rate-regulated enterprises may be directed by their
regulators to retain original historical cost for an impaired asset and to charge
the impairment loss directly to accumulated depreciation. SEC Regulation S-X, Rule
5-02(13)(b), states:
Tangible and intangible utility plant[s] of a public utility
company shall be segregated so as to show separately the original cost, plant
acquisition adjustments, and plant adjustments, as required by the system of
accounts prescribed by the applicable regulatory authorities. This rule shall
not be applicable in respect to companies which are not required to make such a
classification.
Moreover, abandonments and disallowances of plant costs accounted for under ASC
980-360 are outside the scope of ASC 360-10. Entities that recognize impairment
losses on assets subject to cost-based regulation should consider consulting with
their independent auditors.
Bridging the GAAP
If an impairment loss has been recognized for an asset other
than goodwill (or a CGU), IAS 36 requires that an entity reevaluate the
recoverable amount of the asset (CGU) to determine whether an impairment
loss recognized in a prior period no longer exists. If the recoverable
amount of an asset (CGU) has increased since the impairment loss was
recognized, the entity is required to increase the value of the asset (CGU)
to its current recoverable amount. Therefore, the previously recognized
impairment charge would be reversed to profit or loss.
2.7 Depreciation and Amortization Estimates
ASC 360-10
35-22
When a long-lived asset (asset group) is tested for
recoverability, it also may be necessary to review
depreciation estimates and method as required by Topic 250
or the amortization period as required by Topic 350.
Paragraphs 250-10-45-17 through 45-20 and 250-10-50-4
address the accounting for changes in estimates, including
changes in the method of depreciation, amortization, and
depletion. Paragraphs 350-30-35-1 through 35-5 address the
determination of the useful life of an intangible asset. Any
revision to the remaining useful life of a long-lived asset
resulting from that review also shall be considered in
developing estimates of future cash flows used to test the
asset (asset group) for recoverability (see paragraphs
360-10-35-31 through 35-32). However, any change in the
accounting method for the asset resulting from that review
shall be made only after applying this Subtopic.
Entities should continually assess whether, as a result of changes in facts or
circumstances, they need to reassess the method with which, or period over which,
assets are being depreciated or amortized. The presence of an impairment indicator
may signal a reduction in the estimated useful life of an asset even if no
impairment is recognized.
If the entity changes its depreciation or amortization estimates, it should use the
revised estimates for the undiscounted cash flow projections in conjunction with
testing the asset for recoverability. For example, an entity may determine that
because of obsolescence, the useful life of the primary asset (see Section
2.4.4) is three years rather than five years. In such a scenario, the
entity would revise its depreciation estimates for the asset and consider whether
the asset must be tested for recoverability as a result of a triggering event. If
so, the cash flow projections used in the recoverability test should be for three
years. If the asset continues to have service potential, it should not be written
off.
In SAB Topic 5.CC, the SEC staff provided guidance on revising
depreciation estimates for an asset to be abandoned.
SEC Staff Accounting Bulletins
SAB Topic 5.CC, Impairments [Reproduced in ASC
360-10-S99-2]
Standards for recognizing and measuring
impairment of the carrying amount of long-lived assets
including certain identifiable intangibles to be held and
used in operations are found in FASB ASC Topic 360,
Property, Plant, and Equipment. Standards for recognizing
and measuring impairment of the carrying amount of goodwill
and identifiable intangible assets that are not currently
being amortized are found in FASB ASC Topic 350, Intangibles
— Goodwill and Other.
Facts: Company X has mainframe computers that are to
be abandoned in six to nine months as replacement computers
are put in place. The mainframe computers were placed in
service in January 20X0 and were being depreciated on a
straight-line basis over seven years. No salvage value had
been projected at the end of seven years and the original
cost of the computers was $8,400. The board of directors,
with the appropriate authority, approved the abandonment of
the computers in March 20X3 when the computers had a
remaining carrying value of $4,600. No proceeds are expected
upon abandonment. Abandonment cannot occur prior to the
receipt and installation of replacement computers, which is
expected prior to the end of 20X3. Management had begun
reevaluating its mainframe computer capabilities in January
20X2 and had included in its 20X3 capital expenditures
budget an estimated amount for new mainframe computers. The
20X3 capital expenditures budget had been prepared by
management in August 20X2, had been discussed with the
company’s board of directors in September 20X2 and was
formally approved by the board of directors in March 20X3.
Management had also begun soliciting bids for new mainframe
computers beginning in the fall of 20X2. The mainframe
computers, when grouped with assets at the lowest level of
identifiable cash flows, were not impaired on a “held and
used” basis throughout this time period. Management had not
adjusted the original estimated useful life of the computers
(seven years) since 20X0.
Question 1: Company X proposes to recognize an
impairment charge under FASB ASC Topic 360 for the carrying
value of the mainframe computers of $4,600 in March 20X3.
Does Company X meet the requirements in FASB ASC Topic 360
to classify the mainframe computer assets as “to be
abandoned?”
Interpretive Response: No. FASB ASC paragraph
360-10-35-47 provides that “a long-lived asset to be
abandoned is disposed of when it ceases to be used. If an
entity commits to a plan to abandon a long-lived asset
before the end of its previously estimated useful life,
depreciation estimates shall be revised in accordance with
FASB ASC Topic 250, Accounting Changes and Error
Corrections, to reflect the use of the asset over its
shortened useful life.”
Question 2: Would the staff accept an adjustment to
write down the carrying value of the computers to reflect a
“normalized depreciation” rate for the period from March
20X3 through actual abandonment (e.g., December 20X3)?
Normalized depreciation would represent the amount of
depreciation otherwise expected to be recognized during that
period without adjustment of the asset’s useful life, or
$1,000 ($100/month for ten months) in the example fact
pattern.
Interpretive Response: No. The mainframe computers
would be viewed as “held and used” at March 20X3 under the
fact pattern described. There is no basis under FASB ASC
Topic 360 to write down an asset to an amount that would
subsequently result in a “normalized depreciation” charge
through the disposal date, whether disposal is to be by
sale, abandonment, or other means. FASB ASC paragraph
360-10-35-43 requires the asset to be valued at the lower of
carrying amount or fair value less cost to sell in order to
be classified as “held for sale.” For assets that are
classified as “held and used” under FASB ASC Topic 360, an
assessment must first be made as to whether the asset (asset
group) is impaired. FASB ASC paragraph 360-10-35-17
indicates that an impairment loss shall be recognized only
if the carrying amount of a long-lived asset (asset group)
is not recoverable and exceeds its fair value. The carrying
amount of a long-lived asset (asset group) is not
recoverable if it exceeds the sum of the undiscounted cash
flows expected to result from the use and eventual
disposition of the asset (asset group). The staff would
object to a write down of long-lived assets to a “normalized
depreciation” value as representing an acceptable
alternative to the approaches required in FASB ASC Topic
360.
The staff also believes that registrants must continually
evaluate the appropriateness of useful lives assigned to
long-lived assets, including identifiable intangible assets
and goodwill. In the above fact pattern, management had
contemplated removal of the mainframe computers beginning in
January 20X2 and, more formally, in August 20X2 as part of
compiling the 20X3 capital expenditures budget. At those
times, at a minimum, management should have reevaluated the
original useful life assigned to the computers to determine
whether a seven year amortization period remained
appropriate given the company’s current facts and
circumstances, including ongoing technological changes in
the market place. This reevaluation process should have
continued at the time of the September 20X2 board of
directors’ meeting to discuss capital expenditure plans and,
further, as the company pursued mainframe computer bids.
Given the contemporaneous evidence that management’s best
estimate during much of 20X2 was that the current mainframe
computers would be removed from service in 20X3, the
depreciable life of the computers should have been adjusted
prior to 20X3 to reflect this new estimate. The staff does
not view the recognition of an impairment charge to be an
acceptable substitute for choosing the appropriate initial
amortization or depreciation period or subsequently
adjusting this period as company or industry conditions
change. The staff’s view applies also to selection of, and
changes to, estimated residual values. Consequently, the
staff may challenge impairment charges for which the timely
evaluation of useful life and residual value cannot be
demonstrated.
An entity must also disclose information about its depreciation policies in
accordance with ASC 360-10-50-1, which states:
Because of the significant effects
on financial position and results of operations of the depreciation method or
methods used, all of the following disclosures shall be made in the financial
statements or in notes thereto:
- Depreciation expense for the period
- Balances of major classes of depreciable assets, by nature or function, at the balance sheet date
- Accumulated depreciation, either by major classes of depreciable assets or in total, at the balance sheet date
- A general description of the method or methods used in computing depreciation with respect to major classes of depreciable assets.
2.8 Assets That Provide No Future Benefit
An entity may determine that a specific asset within a larger asset
group has no future benefit (e.g., when the asset is destroyed [as opposed to
damaged], becomes obsolete, or is lost). Even if the asset group is determined to be
recoverable as a whole, the entity would need to write off an asset that has no
future benefit.
Example 2-4
Entity A provides ground delivery services
to its customers through a fleet of trucks. Entity A has
appropriately determined that its ground delivery business
represents a “lowest level” for which identifiable cash
flows are largely independent of the cash flows of other
assets and liabilities. One truck in its delivery fleet has
been destroyed in an accident. Entity A can continue to
provide ground delivery services at the same level by using
the remaining trucks in its fleet in such a way that the
destroyed truck is not expected to be replaced. Although A
expects no adverse change in expected cash flows as a result
of the loss of the truck, A must write off the asset that
was destroyed.
An entity often maintains insurance to mitigate losses in the event
of property damage or casualty losses. Even if an asset is insured, the entity would
recognize a loss to write off the damaged asset and separately recognize any
recovery. The recognized loss to write off an asset and any associated recovery
proceeds (through insurance proceeds or other sources of recovery) is treated as two
separate events and therefore two separate units of account. The principle
underlying this separation is derived from the involuntary conversion guidance
codified in ASC 610-30-25-2.
2.9 Presentation of an Impairment Loss
ASC 360-10
Presentation of Impairment Loss for Long-Lived Assets
to Be Held and Used
45-4
An impairment loss recognized for a long-lived asset (asset
group) to be held and used shall be included in income from
continuing operations before income taxes in the income
statement of a business entity. If a subtotal such as income
from operations is presented, it shall include the amount of
that loss.
ASC 360-10-45-4 provides guidance on presentation of an impairment loss. An entity
must present an impairment loss recognized for a long-lived asset (asset group) in
income from continuing operations. If, instead of income before income taxes, the
entity presents a similar subtotal, such as income from operations or operating
income, it should include the impairment loss. The entity may present an impairment
loss as a separate line item in income from continuing operations to meet the
disclosure requirement in ASC 360-10-50-2.
Connecting the Dots
As described in ASC 360-10-35-4, depreciation is a “system of accounting
which aims to distribute the cost or other basic value of tangible capital
assets, less salvage (if any), over the estimated useful life of the [asset]
in a systematic and rational manner. It is a process of allocation, not of
valuation.” As a result, impairment losses should not be recognized in
depreciation or amortization expense.
ASC 360-10-40-3A through 3C describe the guidance an entity should apply to
derecognize an asset (asset group) that represents a (1) nonfinancial asset or (2)
business:
40-3A An entity shall account for the derecognition of a
nonfinancial asset, including an in substance nonfinancial asset and an asset
subject to a lease, within the scope of this Topic in accordance with Subtopic
610-20 on gains and losses from the derecognition of nonfinancial assets, unless
a scope exception from Subtopic 610-20 applies. For example, the derecognition
of a nonfinancial asset in a contract with a customer shall be accounted for in
accordance with Topic 606 on revenue from contracts with customers.
40-3B An entity shall account for the derecognition of a
subsidiary or group of assets that is either a business or nonprofit activity in
accordance with the derecognition guidance in Subtopic 810-10.
40-3C If an entity transfers a nonfinancial asset in
accordance with paragraph 360-10-40-3A, and the contract does not meet all of
the criteria in paragraph 606-10-25-1, the entity shall not derecognize the
nonfinancial asset and shall follow the guidance in paragraphs 606-10-25-6
through 25-8 to determine if and when the contract subsequently meets all the
criteria in paragraph 606-10-25-1. Until all the criteria in paragraph
606-10-25-1 are met, the entity shall continue to do all of the following:
- Report the nonfinancial asset in its financial statements
- Recognize depreciation expense as a period cost unless the assets have been classified as held for sale in accordance with paragraphs 360-10-45-9 through 45-10
- Apply the impairment guidance in Section 360-10-35.
For additional guidance on accounting for a sale of nonfinancial
assets, see Deloitte’s Roadmap Revenue Recognition.
2.10 Disclosures Related to Recognition of an Impairment Loss
In the period in which an entity recognizes an impairment loss, it
should disclose the information required by ASC 360-10-50-2.
ASC 360-10
Impairment of Long-Lived Assets Classified as Held and
Used
50-2 All
of the following information shall be disclosed in the notes
to financial statements that include the period in which an
impairment loss is recognized:
- A description of the impaired long-lived asset (asset group) and the facts and circumstances leading to the impairment
- If not separately presented on the face of the statement, the amount of the impairment loss and the caption in the income statement or the statement of activities that includes that loss
- The method or methods for determining fair value (whether based on a quoted market price, prices for similar assets, or another valuation technique)
- If applicable, the segment in which the impaired long-lived asset (asset group) is reported under Topic 280.
2.11 Early-Warning Disclosures When Future Impairments Are Reasonably Possible
ASC 360-10 does not specifically require entities to provide
“early-warning” disclosures when it is reasonably possible that an impairment may be
recognized in the near future (e.g., when expected future cash flows on an undiscounted basis exceed the asset by only a small amount or when partial impairments are recognized). As described in paragraph B57 of the Background Information and Basis for Conclusions of FASB Statement 144, the Board decided that
entities did not need to provide any specific disclosures in such cases because the
disclosure requirements in ASC 275-10 related to risks and uncertainties associated
with the use of estimates in the preparation of the entity’s financial statements
would be relevant.
ASC 275-10
Certain Significant Estimates
50-6
This Subtopic requires discussion of estimates when, based
on known information available before the financial
statements are issued or are available to be issued (as
discussed in Section 855-10-25), it is reasonably possible
that the estimate will change in the near term and the
effect of the change will be material. The estimate of the
effect of a change in a condition, situation, or set of
circumstances that existed at the date of the financial
statements shall be disclosed and the evaluation shall be
based on known information available before the financial
statements are issued or are available to be issued (as
discussed in Section 855-10-25).
50-7
Various Topics require disclosures about uncertainties
addressed by those Topics. In particular, Subtopic 450-20
specifies disclosures to be made about contingencies that
exist at the date of the financial statements. In addition
to disclosures required by Topic 450 and other accounting
Topics, this Subtopic requires disclosures regarding
estimates used in the determination of the carrying amounts
of assets or liabilities or in disclosure of gain or loss
contingencies, as described below.
50-8
Disclosure regarding an estimate shall be made when known
information available before the financial statements are
issued or are available to be issued (as discussed in
Section 855-10-25) indicates that both of the following
criteria are met:
- It is at least reasonably possible that the estimate of the effect on the financial statements of a condition, situation, or set of circumstances that existed at the date of the financial statements will change in the near term due to one or more future confirming events.
- The effect of the change would be material to the financial statements.
ASC 360-10 also includes an example illustrating how an entity might disclose
information about a potential impairment.
ASC 360-10
Example 12: Specialized Equipment — Potential
Impairment
55-50
Offshore Industries is a manufacturer of offshore drilling
rigs and platforms. The entity’s manufacturing process
requires significant specialized equipment, which it
currently owns. As a result of a decline in the price of
oil, the demand for its products and services has fallen
dramatically in the past two years, resulting in a
significant underutilization of its manufacturing capacity.
55-51
The entity depreciates its investments in specialized
equipment based on its original estimate of the remaining
useful lives of the equipment using the units-of-production
method, since it believes that the exhaustion of usefulness
of these specialized assets relates more to their use than
to the passage of time. The entity reevaluates these
estimates in light of current conditions in accordance with
generally accepted accounting principles (GAAP). The entity
also monitors the policies of its major competitors and is
aware that several have reported large write-downs of
similar assets. Nevertheless, while the entity believes that
it is at least reasonably possible that its estimate that it
will recover the carrying amount of those assets from future
operations will change during the next year, it believes it
is more likely that conditions in the industry will improve
and that no write-down for impairment will be necessary.
55-52
The entity would make the following disclosure:
Offshore’s policy is to depreciate specialized manufacturing
equipment (with a net book value of $25 million at December
31, 19X7) over its remaining useful life using the
units-of-production method and to evaluate the remaining
life and recoverability of such equipment in light of
current conditions. [Given the excess capacity in the
industry,] it is reasonably possible that the entity’s
estimate that it will recover the carrying amount of this
equipment from future operations will change in the near
term.
55-53
Regarding the preceding illustrative disclosure, if the
information in the first sentence is already disclosed
elsewhere in the notes, it need not be repeated. Also, the
bracketed material in the second sentence represents an
example of voluntary disclosure that is encouraged by
paragraph 275-10-50-9.
55-54
In this Example, the entity acknowledges that the carrying
amount of the specialized assets is subject to significant
uncertainty based on current conditions. The uncertainty
relates to the measurement of the specialized assets at the
date of the financial statements, and the entity’s
disclosure makes clear that it is at least reasonably
possible that the carrying amount will change in the near
term.
SEC Considerations
SEC Regulation S-K, Item 303(b)(2), requires registrants to
discuss in MD&A a known uncertainty — specifically, to disclose the
potential for a material impairment charge — in light of potential
impairment triggers. In addition, the SEC staff has stated that it expects
consistency between assumptions and estimates used to estimate expected
future cash flows for impairment analyses and MD&A. For example, the SEC
would challenge a registrant that uses pessimistic assumptions in estimating
expected future cash flows to support an impairment write-down while
describing an optimistic outlook for operations in MD&A. MD&A
disclosures should be consistent with management’s support for expected
future cash flows for testing impairment under ASC 360-10. See Section 8.8 for more
information about required impairment disclosures for SEC registrants.