The U.S. Chamber of Commerce (“Chamber”) appreciates the opportunity to comment on the Financial Accounting Standards Board’s (“FASB” or “Board”) Exposure Draft of a proposed Accounting Standards Update, Income Taxes (Topic 740): Improvements to Income Tax Disclosures (“Proposal” or “Exposure Draft”).

The Proposal would impose significant additional income tax disclosure requirements in two areas: rate reconciliation and income taxes paid. It would require companies to disclose a variety of disaggregated quantitative and qualitative information in each of these areas, including information by individual jurisdictions (i.e., federal (national), state and local, and foreign). And it includes requirements for both annual and interim reporting that would, in some form, apply to all entities subject to income taxes.

While the Chamber supports FASB in its mission to develop standards of financial
reporting that provide investors and other users with material, decision-useful information, we continue to have serious concerns about this project, as previously expressed to FASB.Because these concerns now extend to the Proposal itself, we reiterate and expand on them below. And when considered in conjunction with the additional concerns raised herein, it becomes clear that the Proposal’s infirmities are sufficiently extensive to warrant its immediate withdrawal and reconsideration