Fair Value and The IASB/FASB Conceptual Framework Project: An Alternative View
Fair Value and The IASB/FASB Conceptual Framework Project: An Alternative View
Fair Value and The IASB/FASB Conceptual Framework Project: An Alternative View
GEOFFREY WHITTINGTON
ORIGINAL
ABACUS
©
1467-6281
0001-3072
Abacus
ABAC
XXX
FAIR
2008
VALUE
Accounting
Blackwell
Melbourne, ARTICLES
AND THE
Foundation,
Publishing
Australia CONCEPTUAL
Asia Unviersity
FRAMEWORK:
of Sydney AN ALTERNATIVE VIEW
This paper analyses various controversial issues arising from the current
project of the IASB and FASB to develop a joint conceptual framework
for financial reporting standards. It discusses their possible implications
for measurement and, in particular, for the use of fair value as the pre-
ferred measurement basis. Two competing world views are identified as
underlying the debate: a Fair Value View, implicit in the IASB’s public
pronouncements, and an Alternative View implicit in publicly expressed
criticisms of the IASB’s pronouncements. The Fair Value View assumes
that markets are relatively perfect and complete and that, in such a setting,
financial reports should meet the needs of passive investors and creditors
by reporting fair values derived from current market prices. The Alterna-
tive View assumes that markets are relatively imperfect and incomplete
and that, in such a market setting, financial reports should also meet the
monitoring requirements of current shareholders (stewardship) by report-
ing past transactions and events using entity-specific measurements that
reflect the opportunities actually available to the reporting entity. The
different implications of the two views are illustrated by reference to
specific issues in recent accounting standards. Finally, the theoretical
support for the two views is discussed. It is concluded that, in a realistic
market setting, the search for a universal measurement method may be
fruitless and a more appropriate approach to the measurement problem
might be to define a clear measurement objective and to select the
measurement method that best meets that objective in the particular
circumstances that exist in relation to each item in the accounts. An
example of such an approach is deprival value, which is not, at present,
under consideration by the IASB.
Key words: Conceptual framework; Fair value; Financial reporting;
International accounting standards; Measurement.
The project by the IASB and FASB to develop a joint conceptual framework,
derived from their existing frameworks, is likely to influence the development of
accounting standards for many years to come. It is therefore not surprising that
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the first discussion papers resulting from the project have attracted much fiercer
criticism than the standard setters seem to have anticipated, or that much of this
criticism has come from within the European Union, which is committed to
adopting the International Financial Reporting Standards (IFRS) of the IASB.
The issue that seems likely to attract most controversy is that of measurement,
which has not yet reached discussion paper stage within the conceptual frame-
work project. In particular, the IASB’s perceived preference for fair value as a
measurement objective is likely, if expressed in the conceptual framework discus-
sions, to be strongly contested. This issue has already been raised by an earlier
discussion paper issued (but not endorsed) by the IASB, and authored by staff of
the Canadian Accounting Standards Board (2005), which praised the positive
properties of fair value.1 Controversy has been stirred further by the IASB’s pub-
lication, as a discussion paper (November 2006), of the FASB’s SFAS 157 (2006),
which attempts to prescribe the interpretation of fair value within FASB standards
as being a current market sale price, ignoring transaction costs and free of entity
specific assumptions. Many critics feel that the adoption of this within IASB
standards would change present practice significantly and adversely, because IFRS
apply fair value more widely to non-financial assets than do FASB standards. Sale
prices are seen as less relevant and less reliable in the case of non-financial rather
than financial assets.
Although fair value is a focus for much of the recent criticism of the IASB’s
standards and is also likely to be so for its conceptual framework project, the
reasons for the criticism lie in other elements of the framework. Critics of fair value
are, in fact, offering an alternative world view of financial reporting, although this
view is usually not well articulated. Nor, for that matter, is the fair value world
view well articulated: the argument is usually conducted on the basis of accepting
a few simple assumptions that make fair value seem to be an obvious choice,
whereas the assumptions themselves should be under discussion.
The objective of this paper is to make some progress towards identifying these
alternative world views and therefore to clarify the nature of the dispute about
the conceptual framework in general and fair value in particular. The perspective
is that of the IASB, of which the author was a member from 2001 to 2006, rather
than the FASB, which is its partner in the project. The author’s own experiences
in writing a number of alternative views to IASB drafts and standards inform the
discussion.2 These were written piecemeal, but gradually a more coherent pattern
began to be apparent, which expressed a different set of assumptions, or world
1
The paper discusses specifically measurement on initial recognition, but the discussion has wider
application.
2
An alternative view is a note explaining the view of a Board member who did not vote in favour of
issuing a particular exposure draft or standard (in the latter case, it is described as a ‘dissenting
view’). The Alternative View developed in this paper is consistent with a number of such views but
also draws on the views of external critics of the IASB: it therefore has no claim to be an expression
of the views of particular members of the IASB, and it is a ‘world view’ rather than a comment on
a particular draft or standard.
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view, described here as the Alternative View. This is in contrast with the view that
is implicit in many of the IASB’s pronouncements, described here as the Fair
Value View. This account is likely to be subjective and incomplete, and there are
likely to be many other world views. However, when there is such a fierce debate
between supporters and opponents of a view, it must surely help understanding to
identify the main sources of disagreement. It must also be acknowledged that
some of the contentious issues arise within the existing conceptual frameworks,
but, as the frameworks are being revised, it is appropriate to question them.
The paper proceeds as follows. First, a description is given of the current
project to develop a joint conceptual framework for the IASB and FASB, includ-
ing its motivation and objectives. Next, there is a discussion of the controversial
aspects of the first two draft chapters of the new framework, on the purpose of
financial reporting and the desirable properties of accounting information, which
have already been issued in discussion paper form. This is followed by a discussion
of the issues raised by the subsequent chapters of the new framework that are
currently in various stages of development, including definition of the elements of
accounts, recognition and measurement. An attempt is then made to identify the
two competing world views represented by opposing sides of the arguments on
specific issues. We then consider how these competing views have been reflected
in past IASB pronouncements, and in alternative views expressed on them. We
conclude by considering the theoretical support for the Alternative View.
Both the FASB and the IASB already have conceptual frameworks. The FASB’s
was the first, dating mainly from the 1970s, and consists of seven substantial
concepts statements, each published separately.3 The IASB’s Framework for the
Preparation and Presentation of Financial Statements (1989) is a much briefer
single document of 110 paragraphs, dating from 1989. Its content shows a strong
affinity with the FASB’s earlier work, although there are important differences of
detail. One important similarity is that, like the FASB framework, it lacks a treat-
ment of measurement and is therefore incomplete. This is a legacy of the fierce
and unresolved debates that took place particularly in the 1970s, when standard
setters struggled unsuccessfully to achieve a solution to the inflation accounting
problem that would be accepted by both users and preparers of accounts.
Another legacy of the pressures and controversies of that period is that both
frameworks emphasize decision usefulness, particularly to investors in capital
markets, as the primary focus of general purpose financial statements. This was a
bold step at the time, sweeping away the traditionalist view that accounting is
primarily for legal and stewardship purposes, with decision usefulness as a useful
3
A valuable ‘insider’ account of the development of the FASB Conceptual Framework is given by
Storey and Storey (1998). An authoritative account of the development of the IASC Framework is
in Camfferman and Zeff (2007, Chapter 9).
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Table 1
possible additional benefit. It is argued later that this change of focus may be
carried too far by the current revision of the frameworks.
A primary motivation for the joint project is to converge the frameworks of
the two boards in order to provide a consistent intellectual foundation for the
convergence of the two sets of standards, to which both boards committed
themselves in the Norwalk Agreement of 2002. Convergence is not, however, the
only motivation: improvement is equally important.4 There are two aspects to
improvement: filling gaps to achieve completeness, and removing internal contra-
dictions to improve consistency. The most obvious gap that needs to be filled is to
develop guidance on measurement. There are many aspects of the coherence of
the IASB’s framework that need improvement. An area that has given particular
difficulty recently is the definition of a liability and especially the distinction
between a liability and equity.
The joint project started in 2005. Its planned sequence of topics and current
achievements is listed in Table 1. The working papers for the project are devel-
oped by a joint IASB/FASB staff team, there being a different staff team for each
stage. FASB’s greater staff resources mean that they are usually in the majority,
although staff from the Canadian standard-setting body are currently developing
the proposals on elements and recognition. Each paper is discussed by both
boards, usually separately but sometimes in joint meetings. Thus, the project is
truly a joint one, although the greater bulk of the FASB’s existing framework and
4
Bullen and Crook (2005) provide a staff overview of the objectives.
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its strong staff input mean that the starting point tends to be the FASB’s existing
document rather than the IASB’s. In most aspects, there is little difference
between the current IASB and FASB frameworks, so that the FASB’s distinct
influence is seen mainly in the bulk and style of exposition and argument (which
may be politely described as ‘thorough’) in the two draft chapters and working
papers that have appeared to date. The present paper is, however, written from
the IASB perspective, and this means that some matters which look like changes
from that perspective are the result of converging with the FASB’s existing position.
The first stage of the revision project (Phase A in Table 1) was initially considered
to be so uncontroversial that it was intended that the first publication would be
an exposure draft, which would be the only public consultation. However, wiser
counsel prevailed and it was decided that the first stage would be (as with all sub-
sequent stages of the revision) a discussion paper, which would be followed later
by an exposure draft. This Preliminary Views paper, entitled The Objective of
Financial Reporting and Qualitative Characteristics of Decision-useful Financial
Reporting Information, was published in July 2006, with the comment period
ending on 3 November. The comments received have demonstrated that the
proposals are controversial and have justified the decision to issue a discussion
paper, allowing further consultation on the subsequent exposure draft. They were
originally conceived as being uncontroversial because they substantially reiterate
much of the material that is in the existing frameworks. However, they do contain
some significant reconstruction of the form and argument, certainly relative to the
IASB’s currently slender document, and these contain the seeds of controversy.5
Moreover, the retention of some of the concepts in the existing framework is also
controversial, particularly in those countries that are recent adopters of IFRS and
that were not involved in the original development of the framework.
5
The first two chapters of the Discussion Paper (including the Basis for Conclusions), covering
objectives and qualitative characteristics, are more than twice as long as the entire existing IASB
Framework.
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assess the amounts, timing and uncertainty of the entity’s future cash inflows and
outflows’ (para. OB3).
This is consistent with the previous Framework, but to newcomers to IFRS it
may seem to understate the special role of present shareholders as the existing
proprietors of the entity. There is certainly a wide range of users of ‘general
purpose’ financial statements, and they have many needs in common, but some
might feel that additionally fulfilling the legitimate needs of present shareholders
in their special role as proprietors is a necessary requirement, whereas other
users have a less compelling claim. This view is expressly rejected, in the Basis for
Conclusions (BC1.8–1.13), on the ground that a broad ‘entity perspective’ is more
inclusive than a narrow ‘proprietary perspective’. This stylization of the proprietary
perspective as being narrow and exclusive is contentious: as the Discussion Paper
admits, all investors have substantial common interests, so the proprietary approach
does not inevitably entail excluding assets and transactions of a group that may be
seen as belonging to outsiders, for example, in the manner of proportional consolida-
tion, but rather might entail more detailed information to existing shareholders
on how their share of the total had changed.
The problem of accommodating the specific needs of present shareholders was
brought into sharp focus by the issue of stewardship, which attracted an alternative
view from two IASB members (AV1.1–1.7) and a substantial volume of adverse
comment subsequently, from the respondents to the public consultation. The Dis-
cussion Paper (OB27–28) acknowledged management’s stewardship obligation to
present owners but claimed that its reporting requirements could be subsumed
within the general objective of decision usefulness, served by providing informa-
tion relevant to future cash flows (OB3, quoted above). Thus, it was not deemed
necessary to specify stewardship as a distinct objective of financial reports.
The reasoning behind this decision is elaborated in BC1.32–1.41. This does not
mark a significant change from the current IASB Framework, which places the
assessment of stewardship second in a list of uses of financial reports ((b) in the
Preface), but asserts that all of the uses are ‘economic decisions’ which will be aided
by similar information. However, the extensive examination of the issue in the
Discussion Paper drew attention to it, and this sidelining of the stewardship objec-
tive was clearly unacceptable to many from countries that were recent adopters of
IFRS and inherited a loftier view of stewardship’s role. The Statement of Principles
of the U.K. ASB, for example, although adopting a broad ‘decision usefulness for
investors’ objective, explicitly states that the objective includes ‘assessing the
stewardship of management’ (1.6). It is notable that both of the authors of the
alternative view were former members of the ASB.
The objection to the subsuming of stewardship into the decision usefulness
objective is, as expressed in the alternative view put forward by IASB members,
that accountability entails more than the prediction of future cash flows. Its
stewardship dimension is concerned with monitoring the past as well as predicting
the future and is sometimes as much concerned with the integrity of management
as with its economic performance (e.g., with respect to management remuneration
and related party transactions). It is therefore concerned more with the past than
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6
Some examples of this balancing process in standards are given later under the heading Reliability
and Prudence.
7
This point is elaborated in the ASB’s response to the Discussion Paper, which is available on the
ASB’s website (http://www.frc.org.uk/asb/press/pub1343.html, accessed, 8 March 2008).
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This chapter, like Chapter 1, claims to retain substantially the principles adopted
in the predecessor frameworks. However, it does make substantial changes in
both form and language, and these are likely to affect the interpretation of the
underlying principles. The main change in form is the sequential approach to
applying the qualitative characteristics, replacing the previous simultaneous
approach in which explicit trade-offs were made. The main change of language is
the replacement of reliability by faithful representation. These changes combine to
eliminate the possibility of a trade-off between relevance and reliability, which
many regarded as an important aspect of the present Framework. This trade-off is
frequently invoked as a reason for not using fair value measurements, which are
perceived as often being relevant but unreliable.8
The sequential approach to applying the characteristics is described in para-
graphs QC42–7 and discussed in BC2.59–2.65. It is explained that relevance
should be considered first because it is essential, and that faithful representation
should be considered next, but that both characteristics are necessary for decision-
usefulness, so that ‘they work in concert with one another’ (QC45). What is
absent from this explanation is an acknowledgement that neither relevance nor
representational faithfulness is an absolute property of accounting information;
rather, there are different levels of relevance and faithful representation, which
opens the possibility of a trade-off between them. If this is ignored, as it appears
to be, the proposed sequence will involve selecting an accounting method first on
the basis of highest relevance and then subjecting this selection to a filter based on
some absolute minimum level of representational faithfulness. Above this thresh-
old there will be no question of saying that greater representational faithfulness
might compensate for less relevance, even if the latter loss is very small.
The substitution of faithful representation for reliability has already weakened
the possibility of such a trade-off. The IASB’s existing definition of reliability is:
Information has the quality of reliability when it is free from material error and bias and
can be depended on by users to represent faithfully that which it either purports to
represent or could reasonably be expected to represent. (IASB Framework, para. 31)
There are significant differences between the two definitions, despite the Discus-
sion Paper’s argument that the new definition is consistent with the intentions of
the existing Framework. Not only is faithful representation elevated to be the
over-riding concept, but now it refers specifically to ‘the real-world economic
8
Walton (2006), a close observer of IASB meetings, notes the possible implications of this change for
the future extension of fair value measurement.
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9
Paton and Littleton (1940, pp. 19–20).
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The Discussion Paper’s position (no prudence) avoids this trade-off, but in
doing so it ignores an important aspect of financial reporting, arising from its
stewardship role. Much of agency theory is concerned with the problem that the
agent has an incentive to exaggerate performance in order to enhance rewards, a
problem that is particularly acute when senior executives are rewarded by stock
options and stock prices are driven by reported financial performance. There have
been a number of recent accounting ‘scandals’ arising from this scenario. In this
context, a ‘degree of caution’ associated with a requirement for ‘more confirma-
tory evidence’ may lead to improved reliability (expressed as confidence by the
user in the information) which will adequately compensate for any possible bias.
A specific example of the exercise of prudence which is an important com-
ponent of the standards of both the IASB and the FASB is the impairment test
(IAS 36). This reduces the carrying amount of an asset to its current recoverable
amount, when that is less than the carrying amount. It does not increase the
carrying amount if the recoverable amount is higher. Hence, it is fundamentally
a biased approach to measurement; it is, however, a prudent one.10 A similar
(biased) measure of liabilities results from the liability adequacy test used in the
IASB’s current standard on Insurance (IFRS 4); this test can result in the carrying
value of a liability being increased but not reduced. In the case of both of these
tests, strict adherence to neutrality would suggest that the adjustment should be
symmetrical, that is, in the case of the impairment test, the asset would always
be carried at current recoverable amount (which could, in some cases, be Fair
Value). The consequences of this for accounting for purchased goodwill, which
has only recently (IFRS 3, 2004) adopted the impairment test in place of
amortization, would be particularly significant and controversial. It was therefore
to be expected that there would be many adverse comments on the proposed
removal of prudence from the Framework. The objectors are not simply clinging
to past practices; they are concerned with inconsistencies with current practice,
some of which has been imposed only recently by the IASB.
10
Bromwich (2004) suggests that impairment tests should not be one-sided.
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in the financial statements, that is, the elements of the income statement, such as
income and expense, must give rise to accrued amounts that are consistent with
the elements of the balance sheet. This approach is a means of imposing discipline
on the assessment of accruals, avoiding the recognition of what Sprouse (1978)
described as ‘What-You-May-Call-Its’. This approach does not require the elevation
of comprehensive income (total gains measured consistently with changes in the
balance sheet) as a central measure of performance, although it might facilitate it.
a resource controlled by an entity as a result of past events and from which future benefits
are expected to flow to the entity. (IASB Framework, 49(a))
An asset is a present economic resource to which the entity has a present right or other
privileged access.
The new definition deletes two significant phrases in the original: ‘as a result of
past events’ and ‘from which future benefits may be expected to flow’. Both of
these are likely to affect the recognition criteria, which have not yet been dis-
cussed in the conceptual framework revision.
The deletion of ‘as a result of past events’ was justified on the ground that it
was superfluous: anything that exists must have come into existence at some time
in the past. However, the deletion does reduce the emphasis on the importance of
past transactions and events, and supporters of the stewardship perspective may
regret this. If the recognition criterion were merely to say that anything which
currently meets the new definition should be recognized as an asset, this would
seem to erode the grounding of recognition in past transactions and events, reduc-
ing the reliability of financial statements. It is less obvious that it would reduce
representational faithfulness, with its emphasis on the representation of ‘real-world
economic phenomena’. Future prospects that have no origin in past transactions
might be regarded as real-world economic phenomena, thus allowing the recogni-
tion, at fair value, of elements of internally generated goodwill that have not
hitherto been regarded as suitable for recognition in financial reports.
The deletion of the reference to expected future benefits suggests that there will
be a future proposal to remove one of the current recognition criteria from the
Framework:
Clearly, 83(a) will have little relevance if expected future benefits no longer form
part of the definition of an asset. The IASB’s reason for the deletion is that the
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phrase has given rise to some confusion, and it must be admitted that this
arises, in part, from the explanation of it in the current Framework (85), which
confuses measurement with recognition. Most elements of financial statements
will have uncertain outcomes and, if the existence of an asset (or liability) is
certain, the fact that its associated cash flows are uncertain can be dealt with by
measurement. For example, it is usual to impair debtors for expected losses due to
bad debts, and stocks may be impaired for expected wastage. Impairment tests
are a common way of reflecting expected future cash flows in the measurement
of assets.
The type of uncertainty that is unique to recognition, rather than measurement,
is what the U.K. ASB’s Statement of Principles calls element uncertainty (ASB,
1999, 5.13–5.15). This is uncertainty as to whether the element exists and meets
the definition of an element, and the IASB’s criterion of ‘probable that any future
economic benefit . . . will flow to the entity’ can be interpreted as referring to this
type of uncertainty. An asset is not an asset of the entity, and therefore not recog-
nized in its accounts, if its benefits do not flow to the entity. Such ‘non-assets’ of
the entity would include assets whose existence cannot be established with an
acceptable level of probability, such as internally generated goodwill. This clearly
is an existence (recognition) issue rather than a measurement issue, and the
proposed amendment to the asset definition appears to ignore it. The IASB is
currently wrestling with that same issue in its revision of IAS 37 (liabilities),
where it is attempting to define when a constructive obligation should be recognized
as a liability.
Measurement also is part of the recognition process (83(b)), but this is in rela-
tion to reliability of measurement rather than uncertainty of outcome. It is in this
context that the IASB Framework (85) is potentially confusing, because the
example chosen (credit risk on a receivable) appears to relate to measurement of
an uncertain outcome with known parameters (an outcome with known risk,
which can be priced and therefore dealt with by measurement) rather than to
uncertainty as to what those parameters are (unreliability of measurement itself,
which prevents the reliable pricing of the outcome).
In summary, the IASB’s (and FASB’s) tentative proposals on asset definition
involve two changes that potentially erode the recognition criteria in the current
Framework. The recognition criteria have not yet been addressed as part of Phase
B, and a staff proposal to do so was rejected in July 2007 in favour of continuing
work on the definition of an asset. Critics of fair value may fear that the removal
of ‘past transactions and events’ from the asset definition, the transfer of un-
certainty from recognition to measurement (where fair value might be thought
to capture it effectively) and the possible modification or even removal of the
present reliability of measurement criterion for recognition will open the way for
an extension of the application of fair value measurement.
Liabilities
The asset definition has hitherto received most attention in Phase B, for the
reason that this will provide the foundation for the other elements in the ‘balance
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sheet’ approach. The other element that has received considerable attention is
liabilities, where a parallel definition to that of assets has been proposed. The
IASB’s current Framework definition is:
A liability is a present obligation of the entity arising from past events, the settlement of
which is expected to result in an outflow from the entity of resources embodying
economic benefits. (IASB Framework, 49(c))
Just as the liability definition mirrors that of assets, so do the changes in the
definition. As in the case of assets, the reference to past events is deleted, as also
is the reference to expectation of future flows. Thus, the same implications arise
for assets as for liabilities, particularly with regard to recognition criteria.
As already indicated, the IASB is already confronting recognition criteria in its
revision of IAS 37. It proposes to abolish the concept of provisions, classifying all
former provisions as liabilities. Provisions were liabilities ‘of uncertain timing or
amount’ (IAS 37, para.10) and the IASB’s current thinking is that many liabilities
are subject to a degree of uncertainty that is reflected in their measurement, so
that a sub-category of provisions is unhelpful, despite the fact that it may convey
information about the relative predictability of the respective categories. With
regard to the recognition of liabilities, the IASB has focused on the question of
whether an obligation exists. It has identified a stand-ready obligation, as in a
guarantee or insurance contract, as giving rise to a liability, the uncertainty of
future outflows being reflected in measurement. It is currently exploring the
difficult problem of establishing the circumstances in which a constructive liability
should be recognized when there is no contractual obligation. This is an element
uncertainty issue, but the IASB’s current preference (IASB Update, July 2007) is
to draw up a list of indicators rather than confronting directly the probabilistic
nature of the decision by defining a probability threshold for recognition, such as
‘more likely than not’. These developments are likely to reinforce the possibility
that the IASB, by removing uncertainty criteria from recognition and requiring
that uncertainty should, instead, be reflected in measurement, is moving towards
a position of requiring that the recognition criterion be the existence of a fair
value. Essentially, any expected future cash flow to the entity, however specula-
tive, could be reflected in a fair value that might be said to meet the new element
definition and therefore be recognized.
Equity
The definition of equity and the difficult problem of defining the distinction
between liabilities and equity is another elements issue that will have to be dealt
with in Phase B, but which has not yet been addressed directly, although the
FASB does have a project on the liability/equity distinction, which is being
‘shadowed’ by the IASB. This difficulty arises partly because equity is a residual
category in the current Framework:
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Equity is the residual interest in the assets of the entity after deducting all liabilities.
(IASB Framework, 49(c))
This leads to a wide variety of financial instruments, such as options on equity,
being classified as equity, thus confusing the simple picture that would be given if
there were only one category of equity instruments, issued shares in the holding
company. It also has led to considerable ambiguity at the margin with liabilities:
essentially anything that is not a present obligation to part with economic
resources is equity. This has led the IASB to breach the Framework in one
instance (a promise to settle in shares to the value of a fixed monetary amount is
classified as a liability) and it has issued an exposure draft that proposes to create
another breach (Financial Instruments Puttable at Fair Value, October 2006) by
treating as equity some instruments that have a right to cash settlement and seem
therefore to meet the current definition of a liability.
One of the possible solutions recently explored in this project is the claims
approach, which regards all credits in the balance sheet as ‘claims’, making no
debt/equity distinction. This solves the problem by abolishing it, and is unlikely to
be adopted. However, little enthusiasm has been expressed for moving in the
alternative direction of having two-tier equity, the lowest tier being the claims of
existing shareholders, and the other tier including other equity instruments such
as warrants, options on equity and (in group accounts) minority interests. Such an
approach would accommodate the needs of those who regard present shareholders
as having a special role as the proprietors to whom the directors owe a special
duty of accountability and who are the ultimate controllers of the entity. The
‘entity’ perspective currently favoured by both FASB and IASB makes no conces-
sions to this group and can lead to accounting that makes it quite difficult for
them to establish the gain or loss on their interest in a period.
11
For a further discussion of comprehensive income in this journal, see Cauwenberge and De Beedle
(2007, pp. 1–26).
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volatile measures that mask operating profit, which they would regard as a better
indicator of the entity’s underlying potential for generating future cash flows.
The IASB is still exploring the obvious solution, which is to allow sub-totals such
as operating profit (roughly, revenue less expenses, in the current Framework’s
terms). The difficulty is to define such sub-totals in a way which is based on
sound principles, practical in application, and acceptable to users and preparers of
financial statements.
Phase D of the conceptual framework deals with the reporting entity and has
made more progress than the measurement phase (C), possibly because it is less
controversial. A discussion paper on reporting entity issues is expected to be
published in 2008. This is not to say that the subject is not important or that it is
without controversy (Walker, 2007).
One source of criticism is likely to stem from the rather rigid view currently
favoured by the IASB that only one set of general purpose financial statements is
appropriate for a group entity. The rejection of the importance of separate hold-
ing company accounts is a symptom of the rejection of a proprietary perspective
in favour of an entity perspective, leading to the view that the interests of those
financing the holding company, and particularly the equity shareholders, should
not be given special consideration in financial reporting. The group accounts
would be important under either perspective, but a proprietary view would regard
the holding company accounts as adding useful information from the perspective
of the holding company, for example, showing the extent of its direct control of
assets and legal obligation for liabilities.
MEASUREMENT
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This definition is consistent with either an entry value (such as current cost) or an
exit value (such as selling price), and it does not define a treatment of transaction
costs, so that, for example, it is consistent with net realizable value (selling price
less selling costs being the amount that the seller would receive). These ambiguities
are removed by the recent IASB Discussion Paper based on SFAS 157 (FASB, 2006):
Fair value is the price that would be received to sell an asset or paid to transfer a
liability in an orderly transaction between market participants at the measurement date.
(SFAS157, 5)
Thus, fair value is an exit value (the price received to sell an asset) and transaction
costs are not included (hence the substitution of ‘price’ for ‘amount’). Moreover,
the reference to a market rather than a transaction between parties emphasizes
the requirement that the measure be non entity specific, that is, it should be based
on a hypothetical best market price rather than the price actually paid or that
would be actually obtained by the reporting entity.
The Discussion Paper based on SFAS157 is supposed to be merely a ‘how to do
it’ proposal for existing uses of fair value, rather than extending that use, but the
result of its new definition is to draw the lines clearly between different views of
the appropriate measurement basis. The difference is not now between historical
cost and current value but between entry (cost-based) values and exit (sale) values,
and between those who wish to measure the opportunities available to the specific
entity and those who prefer to use hypothetical market prices.
The Discussion Paper is not strictly part of Phase C of the Framework revision,
although its progress to date is likely to have more impact than that of the Phase
C work. The latter has taken the form of drawing up an inventory of valuation
bases and developing a conceptual approach to measurement that will enable
those methods to be evaluated.
12
Tweedie and Whittington (1984) provide an account of the development of price change account-
ing standards, and Tweedie and Whittington (1997) describes their rejection (mainly by preparers
of accounts) and subsequent withdrawal.
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The nine candidate valuation bases selected for analysis in Phase C do not
include deprival value, once the favourite of standard setters, on the ground that
it is a hybrid measure, derived from a comparison of other measures (current
entry value, current exit value and value in use). This ignores the fact that
deprival value is a coherent valuation objective. Concentrating on the intrinsic
properties of specific measures at the expense of considering how objectives might
be achieved seems to miss the point of accounting, which is to inform users in an
imperfect and uncertain world.13 It seems possible that this type of analysis will
lead to a long and ultimately fruitless debate.
This impression is borne out by the papers on measurement submitted to the
IASB’s July 2007 meeting. After a careful analysis of measurement theory, a revision
of the IASB’s definition of measurement is proposed. The current definition is:
Measurement is the process of determining the monetary amounts at which the elements
of financial statements are to be recognized and carried in the balance sheet and income
statement. (IASB Framework, 99)
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the argument usually focuses on a particular aspect of the framework rather than
the whole system. There is also a variety of individual views within each broad
school of thought, so that a degree of stylization is necessary. However, it may
clarify the debate if the views of the parties are articulated in a holistic manner,
identifying the common ground within each world view and the difference between
that and the competing view.
The two competing models identified here are the Fair Value View and the
Alternative View.14 The latter title is justified because many of its ideas are sup-
ported by alternative views attached to IASB pronouncements. Another reason
for using this rather bland description is that many of the attributes of that view
are too easily associated with consequences that do not necessarily follow from
them. For example, if it were described as ‘a stewardship view’ there could be an
inappropriate belief that this necessarily implied a preference for historical cost
measurement.
14
A similar (but not identical) identification of two schools of thought is made at the end of Andrew
Lennard’s very interesting and insightful paper on ‘Liabilities and How to Account for Them’
(2002).
15
Staff opinions are not expressed in public, but staff recommendations are expressed to the boards,
although only on issues that are referred to them. However, staff do author published papers and
their views are sometimes expressed quite forcefully there (e.g., Johnson, 2005).
16
Directly’ means that the measure summarizes expected future cash flows, as in a discounted
present value.
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• Accounting information needs ideally to reflect the future,17 not the past, so
past transactions and events are only peripherally relevant.
• Market prices should give an informed, non entity specific estimate of cash flow
potential, and markets are generally sufficiently complete and efficient to
provide evidence for representationally faithful measurement on this basis.
The implications of the Fair Value View are:
• Stewardship is not a distinct objective of financial statements, although its needs
may be met incidentally to others.
• Present shareholders have no special status amongst investors as users of
financial statements.
• Past transactions and events are relevant only insofar as they can assist in pre-
dicting future cash flows.
• Prudence is a distortion of accounting measurement, violating faithful representation.
• Cost (entry value) is an inappropriate measurement basis because it relates to a
past event (acquisition) whereas future cash flow will result from future exit,
measured by fair value.
• Fair value, defined as market selling (exit) price, as in SFAS 157(FASB, 2006),
should be the measurement objective.
• The balance sheet is the fundamental financial statement, especially if it is fair
valued.
• Comprehensive income is an essential element of the income statement: it is
consistent with changes in net assets reported in the balance sheet.
17
Mary Barth (2006), an IASB Board member, provides a useful discussion of the orientation of
accounting information towards the future, making clear the distinction between recognition (only
present rights and obligations should be recognized) and measurement (expected cash flows from
those rights and obligations may affect their measurement). She views measurement from a fair
value perspective. Michael Bromwich (2004) provides a discussion of future-oriented information
from an alternative, deprival value perspective. See also Rosenfield’s discussion in this journal of
the way to report ‘prospects’ data within a fair value reporting system (2008, pp. 48 – 60).
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therefore precludes the totally reactionary views (not uncommon among busy
people who are preoccupied with the daily problems of running their business)
that nothing in current practice needs to be changed, that financial reporting
standards are an unnecessary interference in business, and that thinking concep-
tually about accounting is an academic, ivory-tower activity of no relevance to the
real world.18
The main features of the Alternative View are:
• Stewardship, defined as accountability to present shareholders, is a distinct
objective, ranking equally with decision usefulness.
• Present shareholders of the holding company have a special status as users of
financial statements.
• Future cash flows may be endogenous: feedback from shareholders (and markets)
in response to accounting reports may influence management decisions.
• Financial reporting relieves information asymmetry in an uncertain world, so
reliability is an essential characteristic.
• Past transactions and events are important both for stewardship and as inputs to
the prediction of future cash flows (as indirect rather than direct measurement).
• The economic environment is one of imperfect and incomplete markets in which
market opportunities will be entity-specific.
The implications of the Alternative View are:
• The information needs of present shareholders, including stewardship require-
ments must be met.
• Past transactions and events are relevant information and, together with reliability
of measurement and probability of existence, are critical requirements for the
recognition of elements of accounts, in order to achieve reliability.
• Prudence, as explained in the current IASB Framework and in the ASB’s
Statement of Principles, can enhance reliability.
• Cost (historic or current) can be a relevant measurement basis, for example
as an input to the prediction of future cash flows, as well as for stewardship
purposes.
• The financial statements should reflect the financial performance and position
of a specific entity, and entity specific assumptions should be made when these
reflect the real opportunities available to the entity.
• Performance statements and earnings measures can be more important than
balance sheets in some circumstances (but there should be arithmetic consist-
ency—articulation—between flow statements and balance sheets).
18
A feature of standard-setting has been the constructive engagement of the academic and business
communities. Standard-setting bodies have always been well stocked with experienced practitioners,
but there have also been notable academic inputs. For example, David Solomons was a member of
the Wheat Committee that devised the FASB and Robert Sprouse was one of FASB’s first members.
Robert Sterling and Paul Rosenfield were also early members on the FASB. In the U.K., both the
Chairman (David Tweedie) and Vice-Chairman (Brian Carsberg) of the ASB, at its inception,
started their careers as full-time academics.
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A number of the IASB’s proposals (in discussion papers, exposure drafts and
standards) have been subject to strong criticism from constituents and, in some
cases, alternative views from within the Board. The following list is by no means
complete, but it illustrates instances in which criticisms reflect the Alternative
View. The view expressed by the IASB and its partner, the FASB, usually is
consistent with the Fair Value View. This is not surprising because the conceptual
frameworks of the two boards, which guide their work, are also consistent with
that view.
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value in the absence of other measures, at the bottom of the measurement hierar-
chy. This would change current practice in areas such as IAS 16, Property, Plant
and Equipment, and IAS 17, Leases, where replacement cost may seem to be a
more relevant measure of future cash flows for assets that are to be used in the
business, and which therefore represent future costs saved rather than future
revenues earned.
The rejection of cost in favour of fair value selling price at initial recognition is
particularly controversial. This gives rise to ‘day 1’ profits on financial instruments
(IAS 39). Such profits rely on the entity being able to realize the asset at fair value
in the future. Therefore, some would argue that the profits are not yet ‘earned’ at
day 1, which is why retailers are usually required to record their stock at cost
rather than a higher retail price.19
In the exposure draft to revise IFRS 3 on business combinations, the proposal
to change from a cost allocation model to one based on the fair value of the whole
acquired entity has been very controversial, with extensive alternative views by
board members (AV1–20). One of the criticisms made (AV18) is that purchase
consideration including acquisition costs (which would be written off under a fair
value measurement basis) best captures the economic substance of the acquisition
transaction, reflecting the outlay which the acquirer must expect to recover.
19
This type of criticism has a long history—see the discussion of the 1930s ideas of George Husband
described in this journal (Reinstein et al., 2008, pp. 82–108).
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Recognition Criteria
The two recognition criteria in the existing IASB Framework are probability that
the entity will receive future cash benefits (in the case of an asset) and reliability
of measurement. The probability criterion has been eroded by some recent deci-
sions of the IASB.
IFRS 3, Business Combinations, and the consequential amendments to IAS 38,
Intangible Assets, result in the withdrawal of the probability recognition criterion
for intangible assets acquired in a business combination, on the ground that their
measurement is at fair value, which incorporates assessments of probability. As
explained earlier, this ignores element uncertainty, and it is inconsistent with the
treatment of other intangible assets. A dissenting view to IFRS 3 (DO7) addresses
this issue, as does a dissenting opinion on the revised IAS 38 (DO1–3).
Using the same reasoning, IFRS 3 also removes the probability requirement
for contingent liabilities acquired in a business combination because they are
measured at fair value, and this too is addressed in DO7.
20
The Penman paper uses historical cost earnings for illustrative purposes. This does not preclude
current replacement cost, if it were available, from providing an even more useful measure. This is
compatible with the Alternative View expressed in this paper. That view does not deny the potential
usefulness of current values (entry or exit) when they can be reliably measured and are relevant to
the circumstances of the entity.
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The advocates of fair value, and more broadly the Fair Value View, have a con-
sistent view of the world that appears to have attractive attributes of coherence
and simplicity from a theoretical standpoint. It is therefore tempting to dismiss
it as ‘alright in theory but not in practice’. However, it should be noted that the
theoretical underpinnings of the Fair Value View are fairly intuitive and simplistic.
Previous advocates of exit value, notably Chambers (1966) and Sterling (1970),
developed much more comprehensive theories of business reporting and
measurement and would not have been unqualified supporters of the Fair Value
View, as outlined above.21
The Alternative View, on the other hand, arises from a variety of people with
diverse views, commenting on specific issues, often from a practical standpoint.
Thus, on the surface at least, it is possible to regard it as somewhat incoherent,
pragmatic and lacking in theoretical foundations. Such an approach might be dis-
missed as ‘practical but not alright in theory’. Neither of these conclusions would
be correct. As we have seen, the two views are based on different assumptions
about the nature of the economic environment, and it is the accuracy of these
assumptions that determines the relevance of the respective views to accounting
standards.
If we accept that the world is not characterized by perfect and complete markets,
the Fair Value View loses much of its attraction, because it does not relate to
the real world in which standard setters operate. In this sense, it is not ‘alright in
theory’ because good theory, from the standard setter’s perspective, should be
relevant, as well as logically coherent.
The Alternative View, on the other hand, does relate to the real world of market
imperfection, but it does not offer simple, coherent solutions. The solutions that
come out of the Alternative View will have a much greater entity or industry
specificity, perhaps even allowing more judgement, which tends to offend the
orderly instincts of standard setters. However, the Alternative View does not lack
theoretical support. Hicks (1946) is a standard reference for writers on income
measurement, and careful readers of his work (of whom there seem to be fewer
than those who refer to it) will recall that Hicks confined his analysis of income to
static theory (not a realistic view of the business world) and rejected its use in
dynamic analysis. In that context, he wrote of Income, Saving and Depreciation:
In spite of their familiarity, I do not believe that they are suitable tools for any analysis
which aims at logical precision. There is far too much equivocation in their meaning,
equivocation which cannot be removed by the most painstaking effort. At bottom, they
are not logical categories at all: they are rough approximations, used by the business
man to steer himself through the bewildering changes of situation which confront him.
21
Chambers’ reservations have been noted earlier (note 13). Sterling was extremely careful to point
out that his ‘conclusions are restricted to trading assets in a trading firm’ (Sterling, 1970, p. 36) and
he acknowledged the difficulties caused by market imperfections. Moreover, unlike the advocates
of fair value, he advocated the deduction of transaction costs from exit prices in order to establish
exit values (p. 327). For a summary of Sterling’s later ideas, see Lee and Wolnizer (1997).
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For this purpose, strict logical categories are not what is needed; something rougher is
actually better. (p. 171).
22
A recent paper by Hitz (2007) evaluates the decision-usefulness of fair value accounting both from
the measurement perspective and from the informational perspective that Beaver and Demski
identify as being the appropriate role for financial reporting in a realistic setting of imperfect and
incomplete markets. The conclusion of this evaluation is that the case for fair value measurement
is supported only when reliable market values are available.
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ago, hoped for economists to develop in this way and they have largely achieved
this, by developing tools of analysis, such as game theory or agency theory which
can be applied to specific problems without claiming to provide universal solu-
tions. Such models are already applied in areas of accounting, such as accounting
disclosure.23 It is suggested that the Alternative View is consistent with this type
of theorizing and that it offers more fruitful practical application than the Fair
Value View.
One approach to accounting measurement which contains the elements of this
approach and is already well-established in the academic literature is deprival
value,24 which provides an algorithm for choosing a measurement method (rather
than prescribing one universal method) that is grounded in the economics of the
firm. It is unfortunate, and perhaps indicative of standard setters’ current prefer-
ences, that this approach to defining a measurement objective rather than a single
technique has been omitted from the current list of measurement candidates
being evaluated in the Conceptual Framework revision, on the ground that it is a
hybrid approach, allowing for the use of more than one ‘pure’ measurement
method. Therefore, the economists’ experience might be relevant to standard
setters in their search for a conceptual framework. Perhaps the time has come for
them to stop trying to work financial miracles (such as deriving a universal ‘best’
measurement method from a complex definition grounded in abstract measure-
ment theory) but instead to follow Keynes’ advice and ‘manage to get themselves
thought of as humble, competent people, on a level with dentists’.
references
Accounting Standards Board, FRS, Reporting Financial Performance, ASB, 1992 (revised 1993 and
1999).
——, Statement of Principles for Financial Reporting, ASB, 1999.
Barth, M. E., ‘Including Estimates of the Future in Today’s Financial Statements’, Accounting
Horizons, September 2006.
Beaver, W. H., and J. S. Demski, ‘The Nature of Income Measurement’, The Accounting Review,
January 1979.
Black, F., ‘Choosing Accounting Rules’, Accounting Horizons, December 1993.
Bromwich, M., ‘Aspects of the Future in Accounting: The Use of Market Prices and “Fair Values” in
Financial Reports’, in C. Leuz, D. Pfaff and A. Hopwood (eds), The Economics and Politics of
Accounting, Oxford University Press, 2004.
Bullen, H. G., and K. Crook, Revisiting the Concepts, FASB and IASB, May 2005.
Bush, T., ‘Divided by a Common Language’: Where Economics Meets the Law—US versus non-US
Financial Reporting Models, Institute of Chartered Accountants in England and Wales, 2005.
23
Verrecchia (2004) gives a concise survey of the application of theoretical models to accounting
disclosure. Wagenhofer (2004) provides a broader survey of the application of analytical economic
models to financial reporting.
24
The history of the concept and its role in the inflation accounting debate is surveyed in Tweedie
and Whittington (1984). Recent examples of work relating deprival value to fair value are Bromwich
(2004) and Van Zijl and Whittington (2006). A good example of economic analysis supporting the
use of deprival value is Edwards et al. (1987).
166
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Camfferman, K., and S. Zeff, Financial Reporting and Global Capital Markets: A History of the Inter-
national Accounting Standards Committee, 1973–2000, Oxford University Press, 2007.
Canadian Accounting Standards Board, Measurement Bases for Financial Accounting-Measurement on
Initial Recognition, IASB, November 2005.
Cauwenberge, P. I., and I. De Beedle, ‘On the IASB Comprehensive Income: An Analysis of the Case
for Dual Income Display’, Abacus, March 2007.
Chambers, R. J., Accounting, Evaluation and Economic Behavior, Prentice-Hall, 1966.
——, ‘Second Thoughts on Continuously Contemporary Accounting’, Abacus, September 1970.
——, ‘Third Thoughts’, Abacus, December 1974.
Edwards, E. O., and P. W. Bell, The Theory and Measurement of Business Income, University of
California Press, 1961.
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Hicks, J. R., Value and Capital (2nd ed.), Clarendon Press, 1946.
Hitz, J.-M., ‘The Decision Usefulness of Fair Value Accounting—a Theoretical Perspective’,
European Accounting Review, Vol. 16, No. 2, 2007.
International Accounting Standards Board:
Standards:
IAS 16, Property, Plant and Equipment, amended 2004.
IAS 17, Leases, revised 2004.
IAS 27, Consolidated and Separate Financial Statements, revised 2004.
IAS 36, Impairment of Assets, revised 2004.
IAS 37, Provisions, Contingent Liabilities and Contingent Assets, 1998.
IAS 38, Intangible Assets, amended 2004.
IAS 39, Financial Instruments: Recognition and Measurement, amended 2005.
IAS 41, Agriculture, 2001.
IFRS 2, Share-Based Payment, 2004.
IFRS 3, Business Combinations, 2004.
IFRS 4, Insurance Contracts, 2004.
Exposure drafts:
Proposed Amendments to IFRS 3, Business Combinations, June 2005.
Proposed Amendments to IAS 27, Consolidated and Separate Financial Statements, June 2005.
Proposed Amendments to IAS 37, Provisions, Contingent Liabilities and Contingent Assets, and IAS
19, Employee Benefits, June 2005.
Proposed Amendments to IAS 32, Financial Instruments: Presentation, and IAS 1, Presentation of
Financial Statements: Financial Instruments Puttable at Fair Value and Obligations Arising on
Liquidation, October 2006.
Discussion papers:
Preliminary Views on an Improved Conceptual Framework for Financial Reporting: The Objective of
Financial Reporting and Qualitative Characteristics of Decision-Useful Financial Reporting
Information, July 2006.
Fair Value Measurements, Parts 1 and 2, November 2006.
Preliminary Views on Insurance Contracts, Parts 1 and 2, May 2007.
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Framework for the Preparation and Presentation of Financial Statements, April 1989.
IASB Update, monthly minutes of Board meetings.
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IASB Information for Observers, edited versions of Board papers, on the IASB web site:
www.iasb.org.
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of Robert R. Sterling, New Works in Accounting History, Garland, 1997.
Lennard, A., Liabilities, and How to Account for Them: An Explanatory Essay, Accounting Standards
Board, 2002.
Leuz, C., D. Pfaff and A. Hopwood (eds), The Economics and Politics of Accounting, Oxford Univer-
sity Press, 2004.
Paton, W. A., and A. C. Littleton, An Introduction to Corporate Accounting Standards, American
Accounting Association, 1940.
Penman, S., ‘Financial Reporting Quality: Is Fair Value a Plus or a Minus?’, Accounting and Business
Research, Special Issue: International Accounting Policy Forum, 2007.
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ment of Accounting Thought’, Abacus, March 2008.
Rosenfield, P., ‘Prospects: A Missing Piece of Current Selling Price Reporting’, Abacus, March 2008.
Sprouse, R. T., ‘The Importance of Earnings in the Conceptual Framework’, Journal of Accountancy,
January 1978.
Sterling, R. R., Theory of the Measurement of Enterprise Income, University Press of Kansas, 1970.
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Standards, Financial Accounting Standards Board, 1998.
Tweedie, D. P., and G. Whittington, The Debate on Inflation Accounting, Cambridge University Press,
1984.
——, ‘The End of the Current Cost Revolution’, in C. W. Nobes and T. Cooke (eds.), The Develop-
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Van Zijl, A., and G. Whittington, ‘Deprival Value and Fair Value: A Reconciliation’, Accounting and
Business Research, June 2006.
Verrecchia, R. E., ‘Policy Implications From the Theory-Based Literature on Disclosure’, in C. Leuz,
D. Pfaff and A. Hopwood (eds), The Economics and Politics of Accounting, Oxford University
Press, 2004.
Wagenhofer, A., ‘Accounting and Economics: What We Learn From Analytical Models in Financial
Accounting and Reporting’, in C. Leuz, D. Pfaff and A. Hopwood (eds), The Economics and
Politics of Accounting, Oxford University Press, 2004.
Walker, R. G., ‘Reporting Entity Concept: A Case-Study of the Failure of Principles-Based Regula-
tion’, Abacus, March 2007.
Walton, P., ‘Fair Value and Executory Contracts: Moving the Boundaries in International Financial
Reporting’, Accounting and Business Research, December 2006.
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