Action Alert No. 08-41
October 9, 2008
NOTICE OF MEETINGS
OPEN BOARD MEETING
meetings are available by audio webcast and telephone.)
Wednesday, October 15, 2008, 9:00 a.m.
of FASB Interpretation No. 48 to private entities (estimated
1-hour discussion). The Board will discuss comments received about
the operationality of deferring FASB Interpretation 48, Accounting for
Uncertainty in Income Taxes, for certain nonpublic enterprises.
Previously, the Board decided to defer the Interpretation for nonpublic
pass-through entities based on their federal income tax status. The
Board will discuss comments received on that approach and on
difficulties in its application.
- Open discussion. If necessary, the Board will allow time to
discuss minor issues with staff members on technical projects or
administrative matters. Those discussions are held following regular
Board meetings as topics come up.
OPEN EDUCATION SESSION
Wednesday, October 15, 2008, (following the Board meeting, if
The Board will hold an educational, non-decision-making session to
discuss topics that are anticipated to be discussed at a future Board
meeting. Those topics will be posted to the FASB calendar four
days prior to the education session.
The Board Actions are provided for the information and convenience
of constituents who want to follow the Board’s deliberations. All of the
conclusions reported are tentative and may be changed at future Board
meetings. Decisions are included in an Exposure Draft for formal comment
only after a formal written ballot. Decisions in an Exposure Draft may be
(and often are) changed in redeliberations based on information provided
to the Board in comment letters, at public roundtable discussions, and
through other communication channels. Decisions become final only after a
formal written ballot to issue a final Statement, Interpretation, FSP, or
Statement 133 Implementation Issue.
October 1, 2008 Board Meeting
of FASB Interpretation No. 48 to private entities. The Board
redeliberated the applicability of FASB Interpretation No. 48,
Accounting for Uncertainty in Income Taxes, to private companies.
The Board reached the following decisions on the proposed issuance of one
or more FASB Staff Positions (FSPs) on Interpretation 48:
- Scope of Interpretation 48. The Board decided to retain the
current scope of Interpretation 48; therefore, it still applies to all
entities, public and private, including pass-through entities and
- Guidance for Pass-Through Entities. The Board decided to
develop application guidance for pass-through entities.
- Deferral for Pass-Through Entities. The Board decided on a
one-year deferral of Interpretation 48 for all private pass-through
entities based on the entity’s federal income tax status. The Board
directed the staff to determine whether the proposed scope of the
deferral is viable and will not create unintended consequences.
- Disclosure Requirements of Interpretation 48. The Board
decided to exempt private companies from the disclosure requirements of
paragraphs 21(a) and 21(b) of Interpretation 48. The Board agreed that
private companies should not be exempt from the other disclosure
requirements of that Interpretation.
- Issuance of FASB Staff Positions. The Board expects to issue
three proposed FSPs on Interpretation 48.
- The Board directed the staff to proceed to a draft of a proposed
FSP on the deferral of Interpretation 48 for certain private entities
(see item 3 above). That proposed FSP would include a request for
comments on issues that private pass-through entities have encountered
related to Interpretation 48.
- The Board directed the staff to proceed to a draft of a second
proposed FSP on the applicability to private entities of certain
disclosures required by Interpretation 48 (see item 4 above).
- The Board anticipates that a third proposed FSP will be drafted to
provide guidance on the application of Interpretation 48 to
pass-through entities. This proposed FSP will incorporate comments
received from the proposed FSP discussed in item 5(a) above.
Agenda decision—Determining fair value in a market that is not
active. The FASB chairman announced that the rules of procedure
governing the length of comment periods have been temporarily modified to
allow a window of time within which the FASB can act, in the best interest
of investors and the capital markets, to provide needed guidance.
As part of its discussions on a draft of proposed FSP
FAS 157-d, Determining the Fair Value of a Financial Asset in a
Market That Is Not Active, the Board agreed that the additional
guidance afforded by this FSP is needed to aid practitioners in estimating
the fair value of assets in markets that are not active via application of
the principles contained in FASB Statement No. 157, Fair Value
Measurements. The Board agreed to make proposed FSP FAS 157-d
effective upon issuance; if the proposed FSP is finalized in time,
entities with a calendar year-end would apply the guidance in their
third-quarter financial statements.
In addition, the Board decided that the following transition guidance
should be provided in the proposed FSP:
- Any changes in fair value would be included in an entity’s financial
results; for example, entities with a calendar year-end would include
any changes in fair value in their third-quarter results.
- Retrospective application of the guidance to prior periods would be
The comment period for proposed FSP FAS 157-d will end on October 9,
2008. The Board plans to discuss comments received on the proposed FSP,
and any additional matters, at the October 10, 2008 Board meeting.
FASB DOCUMENTS AVAILABLE
The following exposure documents were issued and are available on the
FSP FAS 157-d, Determining the Fair Value of a Financial Asset
in a Market That Is Not Active (October 3, 2008). Comments are
requested by October 9, 2008.
Statement, Going Concern (October 9, 2008). Comments are
requested by December 8, 2008.
Statement, Subsequent Events (October 9, 2008). Comments
are requested by December 8, 2008.
FUTURE OPEN MEETINGS
The following is a list of open meetings tentatively scheduled through
November. Because schedules may change, please check the FASB calendar before
finalizing your plans. Revisions to this list since the last issue of
Action Alert are highlighted in bold.
Monday, October 20, 2008—FASB/IASB Joint Board Meeting, Norwalk,
Tuesday, October 21, 2008—FASB/IASB Joint Board Meeting, Norwalk,
Wednesday, October 22, 2008—FASB Education Session
October 29, 2008—FASB Board Meeting
Wednesday, October 29, 2008—FASB
Wednesday, November 5, 2008—FASB Board
Wednesday, November 5, 2008—FASB Education Session
November 11, 2008—Investors Technical Advisory Committee
Wednesday, November 12, 2008—FASB Board
Wednesday, November 12, 2008—Emerging Issues Task Force
Thursday, November 13, 2008—Emerging Issues Task
Wednesday, November 19, 2008—FASB Board
Wednesday, November 19, 2008—FASB Education Session
November 25, 2008—FASB Board Meeting
Tuesday, November 25, 2008—FASB