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February 2012


MHMMessenger
    M AY E R H O F F M A N M C C A N N P. C . – A N I N D E P E N D E N T C PA F I R M




    A publication of the Professional Standards Group
    Tests for Impairment of of Intangible Assets

    Companies may soon have more flexibility in testing                   Management would choose one of two options:
    for impairment of indefinite-lived intangible assets, if
    changes exposed for comment by the FASB in January                       •	proceed directly to a determination of the fair value
    2012 are adopted as proposed. This new proposal                            of an indefinite-lived intangible asset, or
    follows closely on the heels of guidance recently
    released for impairment tests of goodwill, and there                     •	start with an assessment of qualitative factors
    are similarities in both the objectives and the overall                    before calculating the fair value of the asset.
    approach. Like the guidance on goodwill, the proposal
    for other indefinite-lived intangible assets responds to              If management opts for the qualitative assessment,
    concerns about the recurring cost and complexity of                   the requirements include the following:
    performing impairment tests, and the proposed relief
    includes an option to use qualitative assessments                       •	 Management would need to evaluate the likelihood
    to determine when additional quantitative testing is                       that events and circumstances, either individually
    necessary. This Messenger highlights the proposed                          or collectively, could have affected the significant
    changes that would apply to other indefinite-lived                         inputs used in determining the fair value of the
    intangible assets, including trademarks, licenses and                      indefinite-lived intangible asset. The FASB’s
    distribution rights.                                                       proposal provides examples of the factors to be
                                                                               considered, and these examples are similar to the
    Highlights of Proposed Changes                                             ones provided in the guidance for goodwill. (See
                                                                               MHM Messenger 2-12.)
    The proposed changes would permit the use of
    qualitative assessments by all kinds of entities –                      •	 Management would also need to consider specific
    public companies, nonpublic companies and not-for-                         factors when evaluating whether it is more likely
    profit organizations. The application of this approach                     than not that the intangible asset is impaired.
    to indefinite-lived intangible assets other than goodwill                  These factors include:
    would work as follows:
                                                                                 •	 changes to the carrying amount of the asset,

                                                                                 •	 positive  and    mitigating                 events         and
                                                                                    circumstances, and

                                                                                 •	 if the entity has made a recent fair value
                                                                                    calculation for an indefinite-lived intangible,
                                                                                    the difference between that fair value and the
                                                                                    current carrying amount.


          roots run deep
®
                                                              TM
                                                                                                                                (Continued on Page 2)
    our
                   © 2 0 1 2 M A Y E R H O F F M A N M C C A N N P . C . 877-887-1090 • www.mhm-pc.com • All rights reserved.
MHMMessenger
(Continued from Page 1)

     The results of the qualitative assessment would                        intangible assets because the qualitative assessment
     determine the next steps. The entity can bypass                        is optional, and there may be circumstances when
     the quantitative assessment of the fair value of                       it would be appropriate for use with these types of
     the asset, if the analysis of all the relevant factors                 assets.
     leads to the conclusion that it is not more likely
     than not that the asset is impaired. If this is not                    Concessions for private companies.
     the case, then management must determine the
     fair value of the asset and compare that value with                    The proposed amendments would provide an
     the carrying amount of the asset to measure the                        exception for nonpublic entities that would exempt
     amount of the required write-off.                                      these entities from disclosing quantitative information
                                                                            about significant unobservable inputs used in fair value
Other Aspects of the Proposal                                               measurement that are categorized within Level 3 of
                                                                            the fair value hierarchy and relate to the accounting
The proposed amendments do not change how or                                and reporting for an indefinite-lived intangible asset
when an entity must measure an impairment loss, nor                         after its initial recognition. The FASB’s reasons for this
do they add any new disclosure requirements; but they                       exception include the beliefs that:
can require considerable judgment to apply, especially
for intangibles such as in-process research and                                •	users of nonpublic entity financial statements have
development. The FASB has included an exception                                  the ability to question management directly about
to the fair value disclosure requirements for nonpublic                          such matters when necessary, and
entities as summarized below.
                                                                               •	most users are generally already informed of a
The need for judgment.                                                           significant impairment loss and the underlying
                                                                                 reasons well before the financial statements are
Under US accounting standards,an intangible asset                                finalized.
that is not subject to amortization must be tested for
impairment annually or more frequently if events or                         Additional Analysis
changes in circumstances indicate the asset might
be impaired. Included in this category are intangible                       The FASB expects to issue the final standard by June
assets whose fair values can involve significant                            2012 after it considers the comments on the exposure
uncertainties. For example, assets acquired in a                            draft and conducts additional outreach. Among other
business combination (or an acquisition by a not-for-                       things, the Board is interested in hearing whether
profit entity) may include intangibles used in R&D                          preparers believe the proposed amendments will
activities and the fair values of these assets may                          reduce overall costs and complexity associated with
depend on uncertainties associated with regulatory                          the current guidance and whether preparers expect
approvals. The FASB acknowledges the level of                               that their entities will choose to perform the qualitative
difficulty in applying qualitative factors to evaluate                      assessment as opposed to proceeding directly to a
assets of this type. But the Board has tentatively                          quantitative impairment test.
decided not to exclude any types of indefinite-lived



                                                                                                                                  (Continued on Page 3)



                     © 2 0 1 2 M A Y E R H O F F M A N M C C A N N P . C . 877-887-1090 • www.mhm-pc.com • All rights reserved.
MHMMessenger
  (Continued from Page 2)



  The comment period ends on April 24, 2012. The
  proposed effective date is for annual impairment
  tests performed for fiscal years beginning after
  June 15, 2012, with early adoption permitted.

  For More Information

  MHM’s Professional Standards Group will provide
  a comment letter to the FASB. We are interested in
  your views on the pros and cons of the proposed
  approach.

  If you have any specific questions, comments or
  concerns, please share them with James Comito
  of MHM’s Professional Standards Group or your
  MHM service professional. James is located in our
  San Diego office and can be reached by email at
  jcomito@cbiz.com and phone at 858-795-2029.




The information in this MHM Messenger is a brief summary and may not include all the details relevant to your situation.
         Please contact your MHM service provider to further discuss the impact on your financial statements.




                   © 2 0 1 2 M A Y E R H O F F M A N M C C A N N P . C . 877-887-1090 • www.mhm-pc.com • All rights reserved.

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Tests for Impairment of of Intangible Assets

  • 1. February 2012 MHMMessenger M AY E R H O F F M A N M C C A N N P. C . – A N I N D E P E N D E N T C PA F I R M A publication of the Professional Standards Group Tests for Impairment of of Intangible Assets Companies may soon have more flexibility in testing Management would choose one of two options: for impairment of indefinite-lived intangible assets, if changes exposed for comment by the FASB in January • proceed directly to a determination of the fair value 2012 are adopted as proposed. This new proposal of an indefinite-lived intangible asset, or follows closely on the heels of guidance recently released for impairment tests of goodwill, and there • start with an assessment of qualitative factors are similarities in both the objectives and the overall before calculating the fair value of the asset. approach. Like the guidance on goodwill, the proposal for other indefinite-lived intangible assets responds to If management opts for the qualitative assessment, concerns about the recurring cost and complexity of the requirements include the following: performing impairment tests, and the proposed relief includes an option to use qualitative assessments • Management would need to evaluate the likelihood to determine when additional quantitative testing is that events and circumstances, either individually necessary. This Messenger highlights the proposed or collectively, could have affected the significant changes that would apply to other indefinite-lived inputs used in determining the fair value of the intangible assets, including trademarks, licenses and indefinite-lived intangible asset. The FASB’s distribution rights. proposal provides examples of the factors to be considered, and these examples are similar to the Highlights of Proposed Changes ones provided in the guidance for goodwill. (See MHM Messenger 2-12.) The proposed changes would permit the use of qualitative assessments by all kinds of entities – • Management would also need to consider specific public companies, nonpublic companies and not-for- factors when evaluating whether it is more likely profit organizations. The application of this approach than not that the intangible asset is impaired. to indefinite-lived intangible assets other than goodwill These factors include: would work as follows: • changes to the carrying amount of the asset, • positive and mitigating events and circumstances, and • if the entity has made a recent fair value calculation for an indefinite-lived intangible, the difference between that fair value and the current carrying amount. roots run deep ® TM (Continued on Page 2) our © 2 0 1 2 M A Y E R H O F F M A N M C C A N N P . C . 877-887-1090 • www.mhm-pc.com • All rights reserved.
  • 2. MHMMessenger (Continued from Page 1) The results of the qualitative assessment would intangible assets because the qualitative assessment determine the next steps. The entity can bypass is optional, and there may be circumstances when the quantitative assessment of the fair value of it would be appropriate for use with these types of the asset, if the analysis of all the relevant factors assets. leads to the conclusion that it is not more likely than not that the asset is impaired. If this is not Concessions for private companies. the case, then management must determine the fair value of the asset and compare that value with The proposed amendments would provide an the carrying amount of the asset to measure the exception for nonpublic entities that would exempt amount of the required write-off. these entities from disclosing quantitative information about significant unobservable inputs used in fair value Other Aspects of the Proposal measurement that are categorized within Level 3 of the fair value hierarchy and relate to the accounting The proposed amendments do not change how or and reporting for an indefinite-lived intangible asset when an entity must measure an impairment loss, nor after its initial recognition. The FASB’s reasons for this do they add any new disclosure requirements; but they exception include the beliefs that: can require considerable judgment to apply, especially for intangibles such as in-process research and • users of nonpublic entity financial statements have development. The FASB has included an exception the ability to question management directly about to the fair value disclosure requirements for nonpublic such matters when necessary, and entities as summarized below. • most users are generally already informed of a The need for judgment. significant impairment loss and the underlying reasons well before the financial statements are Under US accounting standards,an intangible asset finalized. that is not subject to amortization must be tested for impairment annually or more frequently if events or Additional Analysis changes in circumstances indicate the asset might be impaired. Included in this category are intangible The FASB expects to issue the final standard by June assets whose fair values can involve significant 2012 after it considers the comments on the exposure uncertainties. For example, assets acquired in a draft and conducts additional outreach. Among other business combination (or an acquisition by a not-for- things, the Board is interested in hearing whether profit entity) may include intangibles used in R&D preparers believe the proposed amendments will activities and the fair values of these assets may reduce overall costs and complexity associated with depend on uncertainties associated with regulatory the current guidance and whether preparers expect approvals. The FASB acknowledges the level of that their entities will choose to perform the qualitative difficulty in applying qualitative factors to evaluate assessment as opposed to proceeding directly to a assets of this type. But the Board has tentatively quantitative impairment test. decided not to exclude any types of indefinite-lived (Continued on Page 3) © 2 0 1 2 M A Y E R H O F F M A N M C C A N N P . C . 877-887-1090 • www.mhm-pc.com • All rights reserved.
  • 3. MHMMessenger (Continued from Page 2) The comment period ends on April 24, 2012. The proposed effective date is for annual impairment tests performed for fiscal years beginning after June 15, 2012, with early adoption permitted. For More Information MHM’s Professional Standards Group will provide a comment letter to the FASB. We are interested in your views on the pros and cons of the proposed approach. If you have any specific questions, comments or concerns, please share them with James Comito of MHM’s Professional Standards Group or your MHM service professional. James is located in our San Diego office and can be reached by email at jcomito@cbiz.com and phone at 858-795-2029. The information in this MHM Messenger is a brief summary and may not include all the details relevant to your situation. Please contact your MHM service provider to further discuss the impact on your financial statements. © 2 0 1 2 M A Y E R H O F F M A N M C C A N N P . C . 877-887-1090 • www.mhm-pc.com • All rights reserved.