ASC 842 Effective Date: FASB Finalizes Lease Accounting Extension for Private Companies
Many Companies Still Face Significant Lease Accounting Challenges
The Financial Accounting Standards Board (FASB) has finalized a one-year delay in the effective date of ASU 842 Leases for non-public business entities. The details of the proposal, including a description of affected entities, were described in a previous alert.
The new effective date for calendar-year-end preparers that are not public business entities would be Jan. 1, 2021. The effective date for calendar-year-end public business entities, employee benefit plans, and not-for-profit conduit bond obligors is Jan. 1, 2019, and would remain unchanged.
Even with the ASC 842 delay, many private companies still face significant challenges when it comes to building internal controls that will help them identify relevant leases and comply with the new rules. It’s likely that the best solution will be some combination of software and advisory services offered by your CPA firm.
The time to start considering an action plan for ASC 842 compliance is now. For more information on how the new lease accounting standard could impact your business, contact Katy Al-Khalidi at 716.847.2651 for a complementary discussion of your situation and a road-map to lease accounting compliance.
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Lease Accounting Software Selection
Financial Accounting Standards Board’s (FASB’s) new lease accounting standard ASC 842 may require new software for management and reporting purposes
Private entities got some relief from the Financial Accounting Standards Board (FASB) with the recent proposed extension of the effective date for ASC 842, the new lease accounting standard. Compliance has been challenging for many businesses because it involves both a substantive review of lease policies and portfolios (issues we’ve covered in previous articles) and a technical review of the software needed to effectively track and manage information related to leases.
This article is intended to help you understand and evaluate some of the options available in a very crowded marketplace of lease accounting software. To begin your analysis, ask yourself a couple of basic questions:
- Does your business’ current system track the information needed to meet the demands of reporting under the new rule?
- If not, do you want to implement a system focused solely on compliance with financial reporting requirements, or do you want a more complete lease management program?
Three Types Lease Accounting Software
Options fall into three basic categories.
- Excel: Many businesses have been tracking leases on spreadsheets that were created in-house and adapted as needs changed. For businesses with approximately ten or fewer leases, these sheets may continue to support compliance with the new standard, but they will always come with a higher risk of error. The data entry process and the use of formulas programmed in-house are just a few of the pressure points where spreadsheet solutions tend to break down.
- Lease compliance software: If your primary focus is compliance with the new lease standard, some software packages offer more targeted solutions focusing on helping you meet the reporting requirements of the new standard.
- Lease management software: If your business has a higher number of leases, or if you currently struggle to keep track of your leases, you might want to consider a software package that focuses more broadly on lease management, in addition to compliance with the new standard.
Factors to Consider When Selecting Lease Accounting Software
Just like any other software decision, there are several variables to consider when choosing which lease software is the best fit for your business.
- Lease Accounting Software Cost: Prices will vary significantly based on what features you want to include in your system. Be sure to understand up-front if the price quoted includes set-up fees or if you will need to pay an additional amount to get your business up and running on the new program. Other terms to discuss include:
- Annual v. monthly fees-If you’re in a period of growth, it might make sense to avoid a longer-term commitment and to consider software packages that include upgrade options so that you don’t need to start over with a new vendor if you need additional features.
- Cost per user-How many people will need access to the system and how spread out geographically are they? Does the software pricing structure include thresholds where price jumps significantly with an additional user?
- Cost per lease entered-Another place to watch for threshold numbers where price jumps significantly when the number of leases entered increases.
- Quantity of leases: If you’ve evaluated your lease portfolio and you’re still comfortably under ten leases, your existing spreadsheet process might be enough to support compliance with the new standard. There’s no bright line at which a business must invest in lease accounting software, but many will find that a quality software program can save time and improve accuracy even if they manage only a few contracts.
- Type of lease: Software can vary widely in its ability to serve different types of leases. If your business leases a variety of assets such as machinery and equipment, office space and land, you want to make sure that any software you choose supports all of these types of leases. If you’re more focused on one specific type of asset, some vendors offer more targeted software programs designed to better accommodate one type of lease, such as real estate leases.
Lease management functionality:
- How effective is your current system of lease management?
- Are you able to easily identify the number of leases in your system and look up the terms of any given lease?
- Are you missing key deadlines?
If lease management is a strength for your business already, you may not need to invest heavily in software to improve in this area. However, if it’s an area where your business needs to improve, options for lease management software can include the ability to track items such as physical location of your leased assets, upcoming payments, lease extension or termination deadlines and more.
Connect with a Freed Maxick Lease Accounting Software Specialist
With all of these factors in play, choosing and implementing new lease accounting software can be extremely challenging.
Freed Maxick offers support in all phases of the process, from consultation on software selection to outsourcing of the initial data entry and even ongoing maintenance of your lease portfolio in the system.
To learn more about how we can help you evaluate and select the right lease accounting software, contact Katy Al-Khalidi, CPA at 716.847.2651 for a complementary discussion of your lease accounting situation and a road-map for compliance.
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ASC 842 Transition: Three Components Your Lease Accounting Transition Policy Must Include
Understand and consider the different options available as you review your leases, but…
Private entities subject to the Financial Accounting Standards Board’s (FASB’s) new lease accounting standard ASC 842 may get some deadline relief if a recently proposed effective-date extension becomes final, but implementation can still present a significant challenge regardless of the timeline. In order to make the process as smooth as possible, every affected entity should develop a lease accounting transition policy that includes three key things:
- A materiality threshold
- A plan to determine which FASB “practical expedients” will be used, and
- A plan to determine the appropriate application date.
Note that while we recommend setting a transition date and determining which practical expedients you will adopt as you create your policy, the standard does not require that you determine the application date or expedients at the outset. Final decisions on these can be deferred so that information uncovered during the transition period can be considered. It’s important to understand and consider the different options available as you review your leases, but nothing becomes set in stone until the financial reports are issued.
ASC 842 Materiality Threshold
At the outset, management needs to set a threshold for materiality that helps those working on the transition quickly identify which leases need to be reviewed and which are too small to affect the bottom line. This is important, as it will eliminate immaterial contracts from further review and provide valuable time savings.
Practical Expedients for Lease Accounting
In order to help affected businesses with the transition to a new standard, FASB has approved a number of certain implementation shortcuts known as “practical expedients” that are meant to provide transition relief to entities. If your business is working to conform its financial reporting to the new lease accounting rules, you’ll need to review the list of expedients and determine a transition policy that makes sense for your particular circumstances.
Lease Accounting Practical Expedients 1-3: “The Package”
The first three expedients have come to be known as “the package” because an entity can only elect all three of them together or none at all. They are:
- An entity does not need to reassess whether any expired or existing contracts are, or contain a lease.
- For any expired or existing leases, management does not need to reassess its classification in transition if it was correctly classified under the previous standard (ASC 840).
- An entity does not need to reassess initial direct costs for any existing leases.
These three expedients can save a substantial amount of time at implementation. It is important to note that in order to make this election, an entity must have properly identified and recorded leases under ASC 840.
Non-lease Components
This practical expedient allows entities to combine amounts attributable to lease and non-lease components into a single lease component for evaluation for existing lease agreements at transition. Under the new rules, costs that aren’t attributable to the right to use the asset should be valued and recorded separately from the lease liability. For instance, if a copier lease includes a routine repair and maintenance agreement, that agreement must now be valued and recorded separately from the liability. Entities can elect to continue treatment of these costs under the previous standard for leases in effect at the time of transition.
Short-term Exclusion
If a lease is shorter than 12 months at the lease commencement date and does not contain a purchase option that the lessee is reasonably certain to exercise, the reporting entity can elect not to treat it as a right-of-use asset.
Hindsight
FASB’s expedients include the option to classify a lease at transition based on information that was not available when it was created. This can be helpful for businesses evaluating leases that have an option to extend, but there is a potential downside in that some leases may be reclassified from operating to capital.
Land Easements
The rules permit an entity to continue treating existing or expired land easements in the same manner they were accounted for under the previous standard.
Application Date
An entity must elect one of two modified retrospective approach methods to apply the transition provisions in the standard. Under the two methods, application date would be:
- The later of
- The beginning of the earliest comparative period presented in the financial statements or
- The commencement date of the lease, OR
- The beginning of the period of adoption.
Consider the Users of Your Financial Statements
For most of the non-public entities covered by FASB’s proposed extension, we recommend working with your accounting advisor to determine the path that gets you through the transition with the least complication. However, it’s important to remember that private entities might be dealing with a specific audience when it comes to financial statements. If a bank or stakeholder regularly relies on your financial statements, it is important to consider their requirements while reviewing your financial statements.
Connect with a Freed Maxick Lease Accounting Specialist
Private companies subject to the ASC 842 transition will likely need lease accounting consulting support in order to comply even if FASB’s proposed extension is finalized.
For more information on how the new lease accounting standard could affect your business, contact Katy Al-Khalidi, CPA at 716.847.2651 for a complementary discussion of your situation and a road-map for compliance.
Pennsylvania Corporate Nexus Standard Update
Pennsylvania requires taxpayers with economic nexus to file corporate tax reports after 2019
Source: Corporation Tax Bulletin 2019-04, Pennsylvania Department of Revenue, September 30, 2019, ¶204-728 . Get the announcement here.
In Corporation Income Tax Bulletin 2019-04, the Pennsylvania Department of Revenue announced that it will extend the economic nexus theory that the Supreme Court announced for state sales tax obligations in Wayfair to state corporate income tax obligations. In effect, the PA Department of Revenue is replacing their policy of not asserting economic nexus for income tax purposes.
The bulletin states that “Corporations do not need to be physically present in Pennsylvania in order to have nexus for corporate tax purposes. Out-of-state corporations doing business in Pennsylvania must file tax reports if they are taking advantage of the Pennsylvania economic marketplace”.
Taxpayers claiming P.L. 86-272 protection should still file a tax report and complete the necessary schedules to claim the exemption.
Questions? Talk to a Member of the Freed Maxick SALT Team
If you have any concerns or questions about this update, please contact a member of our state and local tax services team at 716.847.2651 or click on the button to reach us via form.
GASB 87: Implementation Guide for Lease Accounting Standard
Requirements of GASB Statement No. 87, Leases
The Governmental Accounting Standards Board (GASB) has issued an Implementation Guide to help clarify, explain and elaborate on the requirements of Statement No. 87, Leases.
The guide provides questions and answers on several key topics related to the lease standard, including:
- Scope and applicability,
- Determining the term of a lease,
- Determining if a lease qualifies for the short-term lease exception,
- Recognition, measurement, and disclosure by lessees,
- Recognition, measurement, and disclosure by lessors,
- Accounting for contracts with multiple components and contract combinations,
- Accounting for modifications and terminations of leases, and
- Sale-leasebacks, lease-leasebacks, and intra-entity leases.
An appendix to the guide contains three illustrations, including:
- Lessee reporting of an equipment lease,
- Lessee reporting of a building lease with a lease incentive, and
- Variable payments that depend on an index or rate.
The new guidance from GASB comes at a time when the Financial Accounting Standards Board (FASB) has proposed a delay in implementing its new lease standards for private companies. GASB has not announced any proposed change in the timetable for implementation of its lease standard.
For Additional Information and Guidance on Lease Standards
Freed Maxick will provide an alert with additional insights on the GASB implementation guide in the weeks ahead.
If you have questions or concerns related to this GASB action or our lease accounting services, please contact us directly at 716.847.2651.
View full articleTrust Residency Rules: Supreme Court Limits State Ability to Tax Trust Income
Trust Residency Rules: Supreme Court Limits State Ability to Tax Trust Income
The U.S. Supreme Court has ruled against a North Carolina law that attempted to collect income tax from a trust based solely on the residence of a beneficiary. The court held that North Carolina’s attempt to tax undistributed trust income based only on the fact that a beneficiary lived within its borders violated the Due Process Clause of the Fourteenth Amendment because the state “lacks the minimum connection with the object of its tax that the Constitution requires” (North Carolina Department of Revenue v. Kimberly Kaestner 1992 Family Trust).
Using Trusts to Manage Wealth Transfers - Good News about Trust Residency Rules and a Helpful Reminder
The ruling may provide some comfort for taxpayers who use (or are considering using) trusts to manage wealth transfers, as it does find that the state’s attempt to tax the trust’s income was an overreach in this instance.
However, the most important takeaway for grantors, trustees, beneficiaries and administrators is an understanding that the impact of state tax laws must be considered not only at the creation of the trust but throughout its administrative life. If your financial plan includes a trust, it should also include regularly scheduled update meetings with the advisors who administer it.
Unusual Circumstances for Kaestner Beneficiaries
States can impose income taxes on trusts based on a variety of different connections with the jurisdiction. A trust could be liable for tax in a state based on any or all of the following factors:
- Location of administrative functions.
- Residence of grantor.
- Residence of trustees.
- Residence of beneficiaries.
- Did not receive any distributions from the trust,
- Had no right to demand or receive any distribution from the trust, and
- Were not certain that they would ever receive a distribution from the trust.
If any of those criteria had not been met, the court may have ruled differently.
The Kaestner opinion does limit a state's ability to tax undistributed trust income based on the residence of a beneficiary. But the court didn't rule that the North Carolina law was unconstitutional. The justices agreed only that North Carolina couldn't tax undistributed income from this trust based on these facts. The circumstances of this case are such that other trusts might with not win a similar challenge.
Freed Maxick Offers Residency Reviews for Trusts
The Kaestner ruling points out the importance of state residency considerations when planning and managing a trust. Individuals with existing trusts should consider reviewing the residency of beneficiaries to determine if a state income tax may have been overlooked or if a state tax refund may be in order.
Those who are planning to manage an asset transfer using a trust in the future need to incorporate state tax rules into their planning and build in a process for updating administrators on any changes in residence of beneficiaries.
For more information on how the Supreme Court’s Kaestner opinion could affect your current or future trust plans, please contact the trust planning professionals at Freed Maxick by clicking on the button, or call me at (716) 847-2651.
How to Register for State Sales Tax: A State-by-State Guide
Once you have determined that you need to register for sales tax, how do you actually accomplish that? As with all things sales tax related, the answer is “It depends”. It depends on which state you are registering with, as they are all similar but each has their differences. Just like the sales tax laws themselves!
Your starting point will be to visit the website of the state’s Department of Taxation and Finance, as it is known in New York, but may be known as the Department of Revenue in other states.
For your reference, a list of links to state sites has been provided below:
As you can see in the table above, many states have online portals where you can create an account to register for sales tax, file your sales tax returns online, respond to notices and check account status. Others will have forms for you to download and complete. Some may charge a registration fee, while others will not.
What can you expect from all of the states you register with? You need to gather and have ready basic information about your company as you complete the registration process. This includes:
- Business name, address, date of formation
- Form of business (corporation, partnership, sole proprietor)
- Members/owners/shareholders names and addresses
- Business activity (what do you sell? When did you start selling it in that state?)
You can expect an average wait time of about 7-10 business days to receive confirmation of your registration. Filing online will produce faster results than paper filing. Using a state portal, where available, may be faster yet.
The process can be tedious, but it is important. The good news is that most states, eager for you to register, have help lines you can call to get assistance with the registration process, if necessary. Once you know you need to register, it’s best not to procrastinate.
For more information on how to register for states sales tax, or to talk with a member of our state and local tax team, please contact Freed Maxick using the form below.
View full articleUpdate on FASB Lease Accounting Standards for Private Companies
Private companies likely to see delay in deadline for implementing new lease accounting rules.
The Financial Accounting Standards Board (FASB, the Board) has proposed a one-year delay in the effective date of ASU 842 Leases for non-public business entities, as defined in the standard. Affected businesses will be required to report lease transactions under the new rule for fiscal years beginning after December 15, 2020. Public business entities, as defined, are still required to adopt this standard for fiscal years beginning after December 15, 2018.
FASB’s rules require that their proposal be submitted for a 30 day public comment period before it is officially finalized, but no opposition is expected. A one-year delay is consistent with comments submitted previously by the American Institute of Public Accountants (AICPA).
FASB Notes Challenges and Costs of Transition
The Board discussed several challenges caused by rule changes that are magnified when a smaller business attempts to transition to a new standard, such as:
- Limited availability of resources needed to comply with a new rule,
- Limited options for training staff on how to apply the new standard,
- Short turnaround after implementation for large public companies results in limited public disclosure of problem areas and few SEC comment letters, and
- Insufficient lead time to assess software solutions and implement internal controls.
In the case of the lease accounting change, the new requirement that certain lease arrangement be recorded as an asset and corresponding liability has led to a scramble at many businesses to track down documentation of long-standing leases and related amendments.
Once all the documentation is located, the next hurdle is creating a system to manage the process going forward. Depending on the business, there seems to be a tipping point at about 30-40 leases where an in-house spreadsheet becomes unmanageable and a lease management solution from an outside vendor might be a more viable option.
No Time to Relax
The extra time may reduce the pressure on businesses that have been struggling to comply with the new rule, however we strongly advise that implementation is not set aside, but that businesses use this opportunity to continue momentum with reduced stress on your Company personnel.
Most businesses that start the transition process find that it is more complicated and time consuming than they expect. The delay offers a business time to gather the relevant documentation, ask questions about unusual circumstances that may arise, and evaluate software options if needed. A business that simply postpones work on implementation in response to the delay runs the risk of encountering the same problems in a year without any time to implement solutions.
Connect with a Freed Maxick Lease Accounting Specialist
For many private companies, compliance with the upcoming lease accounting standard will be a complex and onerous undertaking. It’s likely that some help will come in the form of a combination of software and advisory services offered by your CPA firm.
The time to start considering an action plan for compliance is now. For more information on how the new lease accounting standard could impact your business, contact Katy DeFilippo at 716.847.2651 for a complementary discussion of your situation and a road-map to compliance.
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Software as a Service Sales Tax: Wayfair’s Impact on SaaS and Digital Goods
If you are a CFO at a business that provides SaaS to clients in multiple states, new state sales tax rules will have an impact on your tax reporting and compliance obligations
A recent Supreme Court case and related law changes in many states have resulted in significant new state sales tax obligations on many SaaS providers. It’s important to understand that these changes could result in new tax collection responsibilities on your business even in states where you have operated without them in the past.
Executives need to act quickly to make sure that their existing operations are in compliance with the new rules and that their systems can adapt as sales growth and law changes trigger additional obligations.
Two Sales Tax Changes That SaaS Providers Need to Consider
Historically, most states have not imposed their sales tax on payments for services. As a result, SaaS providers were not required to collect and remit sales taxes on transactions in those states. In the 16 states that did impose sales tax requirements on cloud-based services, many SaaS providers were still exempt from the obligations because they did not have a physical connection to the jurisdiction, like an office or a server farm. “Physical presence” was the standard used by the Supreme Court to determine if a business established “nexus” in a state. (Nexus is the level of presence that allows a state to tax an out-of-state entity without violating the Constitution’s Commerce Clause.)
These circumstances started to change on June 21, 2018 when the Supreme Court ruled in South Dakota v. Wayfair, Inc. (Wayfair) that economic activity within a state could also establish nexus.
The ruling determined that a sales tax obligation could be established in some circumstances solely through virtual contacts with a state. Most states have since established some variation of an economic nexus standard. The most common variation requires a company to collect and remit sales tax if it has more than $100,000 in sales to the state, or 200 or more transactions delivered into the state during the preceding or current calendar year.
What Wayfair Means for SaaS Providers Now
These changes mean that SaaS providers may now be required to collect and remit sales taxes in states where they have operated for years without any obligation.
If your business crosses the economic nexus threshold in a state that imposes sales tax on services, you will need to bill your clients for those amounts and remit them to the state. In fact, you’ll need to start tracking your transactions in the state from the outset in order to know when you cross a threshold that triggers a sales tax obligation. Subscriptions models increase the likelihood that you could become liable, as a monthly billing cycle would generate twelve transactions per year for each client.
What SaaS Providers Can Expect In the Near Future
We noted above that several states already tax the sale of digital products delivered electronically to their residents. As states evaluate their sales tax laws considering this latest change, it seems likely that many more states will introduce legislation extending their laws into the digital goods sector.
For example, sales of digital products were exempt from sales tax in Iowa until January 1, 2019. Now Iowa taxes electronically transferred digital products such as digital books and audio-visual works. Also, the District of Columbia has recently passed emergency legislation to amend the sales and use tax treatment of digital goods sold or used in the District. Effective January 1, 2019, the definition of “retail sale” in the D.C. Code has been expanded to include charges for or the sale of digital goods, such as digital audio-visual works, digital audio works, digital books, digital codes, digital applications and games, and other taxable tangible personal property delivered electronically.
In addition to digital goods, more states are likely to start taxing SaaS and similar cloud-computing services. For example, effective October 1, 2018, Rhode Island made the sale, storage, and use of vendor-hosted prewritten computer software subject to sales tax, and as of January 1, 2019, SaaS is subject to sales tax in Iowa, but an exemption applies for the sales price of SaaS provided to a business for its exclusive use.
Sales Tax Compliance Strategy for SaaS Providers
Given the Supreme Court’s expansion of nexus to include economic activity, any of the states that expand their sales tax rules to include digital goods and SaaS will easily be able to apply the new requirements to out-of-state businesses. SaaS providers need a sales tax compliance strategy that analyzes where they currently have collection obligations as well as where they are likely to incur them as business grows and laws change.
SaaS and digital goods providers should be working closely with knowledgeable state and local tax advisors to track the obligations created by electronic sales and law changes and ensure proper sales tax collection and compliance.
To learn more about how the SALT experts at Freed Maxick can help your SaaS business manage sales tax obligations across multiple states during this period of significant change, please contact connect with us by clicking on the button or call us at 716-847-2651 to discuss how we can help guide your business through the aftermaths of the Wayfair sales tax case decision.
What is Business Impact Analysis?
Is Your Company Ready for the Business Impact of the Next Natural Disaster?
Throughout 2018, we witnessed numerous natural disasters. From Hurricanes Michael and Florence to the California wildfires, these disasters amounted to billions of dollars of damage. Despite the hurricanes and wildfires that lay siege through the Florida panhandle, Northern California, and the Carolinas, many companies fail to acknowledge the risks of these types of disasters and the detrimental effects they can have on business operations. Sadly, these devastating disasters cannot be prevented, but you can take the necessary steps to protect your business from suffering interruptions to critical systems and processes.
What is a Business Impact Analysis and Why is it Important?
A Business Impact Analysis (BIA) is an evaluation of the possible impact to various processes or systems should an interruption or stoppage occur due to an accident, emergency, or disaster. Simply put, the analysis is a way to predict the negative outcomes of disruption to a business or its processes and develop strategies to help the business recover in the event of an emergency. A BIA can provide a clear picture of the critical or essential systems or processes of your business that must be in place to continue to allow the business to run. By determining which processes or systems are critical, your business is able to address the areas which need to be quickly recovered and the amount of time necessary or allowable to recover them.
An Overview of the Business Impact Analysis Process:
Business Impact Analysis Phase 1: Getting buy-in and the green light from senior management for the BIA project. This will also be the phase where the objectives, goals and scope are defined to provide clarity to the overall project. A project manager, along with a project team, will need to be established, or this can be outsourced to a third party.
Business Impact Analysis Phase 2: Obtaining information and data is the next important phase of the BIA analysis. During this phase, the BIA project team will conduct interviews or provide users with a BIA questionnaire in order to obtain the necessary information. A BIA questionnaire is typically a detailed survey which requests knowledgeable users’ questions about their processes, timing and the maximum allowable time of disruption, any operational, financial, regulatory, and legal or compliance impacts that may arise given a disruption.
Business Impact Analysis Phase 3: Now that key information on the business processes has been collected, the information needs to be analyzed and reviewed. This is done in order to accomplish the following:
- To determine a prioritized listing of business processes or functions, with high criticality at the top of the list.
- To determine which individuals and technology resources are needed to maintain an ideal level of operations.
- To determine the recovery time frame, which is the length of time required to recover a business process of function and bring operations back to normal.
Business Impact Analysis Phase 4: The BIA report and a listing of any findings is now able to be documented. The BIA report is typically presented to senior management and should include the following: an executive summary, the objectives and scope of the analysis, any methodologies used to obtain data and information, a detailed listing of the findings and supporting documentation, and recommendations to be implemented for recovery.
Business Impact Analysis Phase 5: The final BIA report should be presented to senior management in order for them to implement any recommendations or make any adjustments to their strategy planning or goals for the company’s disaster recovery or business continuity plan.
Additionally, a best practice is to complete the BIA every two years, depending on how much the business processes or functions have changed. For some businesses it may be shorter and other businesses it may be longer depending on how much has changed since the last BIA was completed.
Connect with Business Impact Analysis Consultants
At Freed Maxick, our Business Impact Analysis team works with you and your company to understand your process from requirements through deployment to understand the complete picture, not just one area.
For more information about business impact analyses, disaster recovery and business continuity plans or other related risk consulting programs and services, please contact Heather.Jankowski@freedmaxick.com or call 716.847.2651.