Differences in accounting standards and practices

Differences in accounting standards across countries affect the measurement of earnings. These differences, however, are not so great as they are made out to be and they cannot explain away radical departures from fundamental principles of valuation12. Choi and Levich, in a survey of accounting standards across developed markets, note that most countries subscribe to basic accounting notions of consistency, realization and historical cost principles in preparing accounting statements. Table 3.9 summarizes accounting standards in eight major financial markets and reveals that the common elements vastly outnumber those areas where there are differences.

12 At the peak of the Japanese market, there were many investors who explained away the price-earnings multiples of 60 and greater in the market, by noting that Japanese firms were conservative in measuring earnings. Even after taking into account the general provisions and excess depreciation used by many of these firms to depress current earnings, the price-earnings multiples were greater than 50 for many firms, suggesting either extraordinary expected growth in the future or overvaluation.

The two countries that offer the strongest contrast to the United States are Germany and Japan. The key differences and their implications are as follows. First, companies in the United States generally maintain separate tax and financial reporting books, which in turn generates items like deferred taxes to cover differences between the two books. Companies in Germany and Japan do not maintain separate books. Consequently, depreciation methods in financial reports are much more likely to be accelerated and hence to reduce stated income. Second, the requirement that leases be capitalized and shown as a liability is much more tightly enforced in the United States. In Japan, leases are generally treated as operating leases and do not show up as liabilities in the balance sheet. In Germany, firms can capitalize leases, but they have more leeway in classifying leases as operating and capital leases than U.S. companies. Third, goodwill, once created, can be amortized over 40 years in the United States and over much shorter time periods in Germany and Japan, again depressing stated income. Fourth, reserves in the United States can be created only for specific purposes, whereas German and Japanese companies can use general reserves to equalize earnings across periods, leading earnings to be understated during the good years, and overstated during bad years.

Most of these differences can be accounted and adjusted for when comparisons are made between companies in the U.S. and companies in other financial markets. Ratios such as price earnings, which use stated and unadjusted earnings, can be misleading when accounting standards vary widely across the companies being compared.

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