دانلود رایگان مقاله لاتین اظهار نظر SEC مربوط به درآمد سرمایه گذاری از سایت الزویر
عنوان فارسی مقاله:
اسناد اظهار نظر SEC مربوط به درآمد سرمایه گذاری مجدد به طور دائم
عنوان انگلیسی مقاله:
SEC comment letters related to permanently reinvested earnings
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مقدمه انگلیسی مقاله:
1. Introduction
Some analysts estimate that foreign cash balances of US companies are as much as $1.1 trillion (Heller, 2015). Foreign earnings designated as permanently reinvested earnings (PRE) for US multinationals on the Russell 1000 index have grown from approximately $1.1 trillion in 2008 to $2.1 trillion in 2013 (Bank of America, 2014). As a result of growing foreign cash balances and PRE, the foreign operations and tax practices of US multinationals have garnered much attention in the popular press and from members of Congress. Amid concerns that large US multinationals are avoiding US taxes on foreign earnings, senior executives from Hewlett-Packard, Microsoft, and Apple were called to testify before the Permanent Subcommittee on Investigations regarding their tax and financial reporting practices (US Senate Subcommittee on Investigations, 2012, 2013). Although these hearings focused on tax avoidance, scrutiny by the Securities and Exchange Commission (SEC) has focused on registrants with PRE because PRE-related disclosures are one of the few required disclosures about foreign operations. Since PRE-related disclosures alone do not require much detail, the SEC canuse its comment letter process to request more in-depth information about foreign operations. Thus, our focus is on understanding comment letters related to PRE. As noted by Schultz and Fogarty (2009), the information disclosed by US multinational corporations in their 10-K filings related to their foreign operations does not allow users to reasonably estimate or understand the tax implications associated with foreign earnings. While the accounting and disclosure rules around PRE have remained the same since the issuance of APB 23 (AICPA, 1972), the SEC's increased focus on these disclosures through its comment letter process may provide additional information into the disclosure concerns of the SEC. The information contained in a comment letter is often more detailed than the information disclosed in a 10-K filing. Recent analyses suggest that some of the PRE-related inquiries the SEC makes pertain to (1) the impact PRE has on liquidity by understanding how much of PRE is foreign cash, (2) justifications for asserting the indefinite reinvestment criterion, and (3) information about the incremental tax due if the foreign earnings were repatriated to the US parent as a dividend (Deloitte, 2015). Thus, comment letters provide insight into the rationale for disclosure choices companies make when designating earnings as PRE. Therefore, we examine the determinants of receiving a PRE-related comment letter to provide insights into the inquiries about PRE by the SEC. We hypothesize that due to the recent political attention on PRE, firms with large amounts of PRE are more likely to receive a PRErelated comment letter. We also hypothesize that firms with a large estimated hypothetical tax on PRE are more likely to receive a PRErelated comment letter. Since Krull (2004) shows that managers utilize PRE as an earnings management tool, we hypothesize that firms with increases in PRE, which is an indicator for earnings management, are more likely to receive a PRE-related comment letter. Additionally, Eiler and Kutcher (2014) show that managers opportunistically use discretion in the disclosure rules when making their disclosures about the estimated tax due upon hypothetical repatriation of PRE. Thus, managers utilize the flexibility in their disclosures surrounding PRE to reduce transparency. As a result, we hypothesize that firms with less transparent disclosures related to PRE are more likely to receive a PRE-related comment letter.
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کلمات کلیدی:
SEC Comment Letters | Audit Analytics www.auditanalytics.com/blog/category/sec-comment-letters/ The data found in SEC Comment Letters can offer insight into some ... The deficiency related to a failure to properly apply tax accounting and affected the ... [PDF]Technical Line: 2016 trends in SEC comment letters - EY www.ey.com/...CommentsTrends.../TechnicalLine_03099-161US_CommentsTrends_... Sep 29, 2016 - SEC staff comment letters for the year ended 30 June 2016. ... their use of non-GAAP financial measures and their related disclosures and ... SEC comment letter series - IAS Plus https://www.iasplus.com/en-us/tag-types/united-states/sec-comment-letter-series In addition to extracts of letters and links to relevant related resources, these publications contain analysis of staff comments to help registrants understand ... SEC comment letters related to permanently reinvested earnings www.sciencedirect.com/science/article/pii/S0882611016300761 by L Eiler - 2016 - Cited by 1 - Related articles Since PRE-related disclosures alone do not require much detail, the SEC can use its comment letter process to request more in-depth information about foreign ... Searches related to SEC comment letters related sec comment letters publicly available sec comment letters 2016 sec comment letter process sec comment letters deloitte when do sec comment letters become public sec comment letter example comment letter format when are sec comment letters available on edgar
