We—the undersigned organizations representing both issuers and investors, lenders, creditors, and other allocators of capital (collectively, “financial statement users”)—welcome the opportunity to further comment on the proposed Accounting Standards Update (the “Update”) from the Financial Accounting Standards Board (the “Board”), “Income Taxes (Topic 740): Improvements to Income Tax Disclosures.” We continue to be concerned that the proposed Update would produce financial statement disclosures that are misleading to financial statement users. We are also concerned that the process by which the Board ultimately voted to direct the staff to draft a final Update for vote by written ballot fell short of the Guiding Principles and Due Process considerations set forth in the Board’s Rules of Procedure.
