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INthe April, 1957 issue of this Journal with distinct operating divisions which are
Maurice Moonitz presented an analy- virtually separate firms. If attention is
sis of "Income Taxes in Financial focused on the income of the entity, the
Statements"' which urged the allocation of liability for future taxes is likely to be en-
income taxes among statement items in a tirely non-existent in most cases.
variety of cases. In the July, 1957 issue, In deciding whether or not inter-period
Thomas M. Hill2 indicated the reasons for allocation is appropriate and whether a
his opposition to the suggested inter-period liability exists, Moonitz points out two
allocation of income taxes. Both articles controlling questions:
agree that the most important of the areas (a) Are tax rates expected to remain at sub-
of controversy over inter-period allocation stantially their current levels? and
arises from the use of an accelerated-depre- (b) Is taxable income expected to emerge each
ciation method for* tax purposes and year in the foreseeable future?
straight-line depreciation for financial re-
If these two criteria were indeed control-
porting purposes. These comments will be
ling, then recognition of a liability for
confined to a consideration of that ques-
future taxes might be appropriate. Most
tion only.
firms can answer both questions affirma-
In his analysis of this accelerated depre-
tively with at least as much confidenceas
ciation case Professor Moonitz seeks to as-
they place, for example, in the service life
sociate the amount of income tax charges
estimates that control the amount of their
with income produced by individual assets.
This is a well-nigh impossible task for al-
depreciation charges. However, two other
criteria precede those listed by Moonitz.
most all firms. Income typically results
They are:
from a successful blending of a variety of
economic resources, all of which are neces- (1) Are tax rules for depreciation methods ex-
sary to achieve the desired final result. Ef- pected to remain as generous as they now
are? and
forts to allocate the income total to spe- (2) Will a policy of regular investment in
cific assets are likely to be fruitless or mis- assets subject to depreciation be main-
leading. In the usual case income can only tained?
be associated with the firm as a whole or
If the answer to these two questions is af-
I THE AccOUNTING REVIW, April, 1957, pp. 175-
2183
firmative, then there will be no future tax
2 THE~
AccOTJNTING
RyvImw, July, 1957,pp. 357-361. liability and questions (a) and (b) need not
173
be raised. Only if questions (1) and (2) ment of one machine each year has been
cannot be answered favorably is there any made. In company with almost all other
need to consider the other criteria. American firms, our firm has used the
If we focus attention on the total collec- straight-line depreciation method for fi-
tion of depreciating assets of the taxable nancial accounting and tax accounting for
entity rather than on one, or a small many years. Thus the depreciation deduc-
group, of its depreciating assets, the ques- tion in its tax return and income statement
tion is seen in proper perspective. In the in year 0 (1953) and preceding years was
next section the depreciation charges of an $1,500.
artificially simple static firm and of a In year 1 (1954) the firm decided to
steadily growing one will be considered. avail itself of the opportunity to use the
Subsequent sections will deal with the sum-of-the-years-digits method4 of depre-
standards for expense and liability recog- ciation for newly acquired assets for tax
nition and the probability of the non-allo- purposes but it decided to continue to use
cation criteria being realized. straight-line depreciation for financial-re-
Throughout the discussion that follows porting purposes.The depreciationcharges
the only type of allocation considered is from year 0 onward are indicated in Table
inter-period allocation of income taxes 1. During the fouryear periodof transition'
where an accelerated-depreciation method to the new arrangement, depreciation
is used for tax purposes and the straight- deductions for tax purposes exceed those
line method is used for financial reporting for financial-reportingpurposes; in years 5
purposes. This problem would lose a good and 6 and in all years -thereafterdepredia-
bit of its significance, as Moonitz correctly tion deductions for tax and financial ac-
points out, if income taxes were treated as counting are identical, if our two condi-
a distribution, rather than a partial deter- tions of no change in the depreciation pro-
minant, of income. However, he accepts visions of the tax law and continued re-
the premise that income taxes are an ex- placement of retired assets are met.
pense. This analysis will be couched in the Under these conditions, should an entry
same terms, although, for reasons set forth chargingincome and recognizinga liability
elsewhere, I feel treatment of income taxes for "income taxes payable in the future"
as an income distribution results in a more be made in years 1 through 4? Assuming a
meaningful presentation of income.3 50% tax rate, the entry in year 1 would be:
Income tax charges ....... ..... 100
STATIC AND STEADILY Income tax payable in the future .............. 100
GROWING FIRMS 50% of the "extra" depreciation of $200. This
assumes a previous entry recognizing the tax
Although a completely static firm is un- currently payable has been made.
likely to be encountered in the real world, In years 2, 3 and 4 similar entries in the
its artificial simplicity is useful as an ex-
pository device. Let us consider such a 4 If the double-declining-balance method were used,
firm which owns 5 depreciating assets, substantially similar results would be achieved. The
sum-of-the-years-digits method is used in this and
each costing $1,500. The assets were ac- future illustrations because it gives a somewhat greater
quired at the rate of one each year on suc- degree of acceleration and seems to be used somewhat
more widely. Cf. Accounting Trends and Techniques,
cessive New Year's Days and all have serv- Tenth Edition (1956), p. 156.
6 The transition to accelerated depreciation will be
ice lives of five years with zero salvage
accomplished in n-1 years, where n is equal to esti-
value. Since this is a static firm, replace- mated service life of the asset. In a more realistic case of
a firm with a heterogeneous group of assets, the great
I See Mason and Davidson, Fundamentals of Ac- bulk of the transition will be completed in n-1 years,
counting, 3rd Edition, p. 168. where n is equal to weighted average service life.
N.B. All assets have a five-year service life and zero salvage value.
amounts of $150, $150, and $100, respec- tra" depreciation declines to a much
tively, would be made if tax rates are not smaller figure, but grows in every year
altered. Since tax and book depreciation thereafter.If the firm's rate of growth is
deductions are the same in every year after maintained, the "extra" depreciation not
year 4, the liability would remain on the only grows each year but grows by an in-
books in perpetuity unchanged from its creasingamount. If Table 2 were extended,
$500 amount. it would show that in year 20 "extra" de-
A somewhat more realistic model is in- preciation was $144 and by year 30 it
troduced if we consider a firm which grows would amount to $233.6
at a constant rate. In the first year of the If a liability for future taxes were recog-
period under consideration (year -4) it nized under these conditions, the balance
acquires $1,500 of depreciating assets. In- in the liability account would grow each
vestment in depreciating assets grows at a year. After a sufficiently long period, this
5% rate each year thereafter. The case is "liability" might well become one of the
further simplified by again assuming that major balance-sheet items.
all assets have a five-year service life and
zero salvage value. This firm also changes 6 The general formula for the calculation of the "ex-
tra" depreciation assuming a uniform service life (n), a
to the sum-of-the-years-digits method for constant rate of growth (r), and an initial investment of
tax purposes in year 1 and continues to use Xis:
straight-line depreciation for financial ac- Extra depreciation in year y
counting.
Table -2 indicates the results for the -(X(1+r) )
(n(n+1
steadily growing firm. During the transi-
? (X(1 r)v1 (-74 I- +)
tion period, tax depreciation exceeds book
depreciation by substantial amounts. At
the end of the transition period this "ex- + X(x1+rwvu (n-')n? -
Total Depreciation Charge on Tax Return. 1,658 1,996 2,223 2,334 2,324 2,185 2,293 2,407
B. Straight-Line Depreciation in Financial Re-
ports .1,658 1,740 1,827 1,919 2,015 2,115 2,221 2,332
N.B. All assets have a five-year service life and zero salvage value.
CRITERIA FOR RECOGNITION OF The crux of the matter then is whether the
EXPENSES AND LIABILITIES events in these cases have established the
Does a difference in the deduction for existence of a liability.
depreciation on the tax return as compared Concerning liabilities the statement
with the books require an accrual entry in says:
all cases, including of course the two ex- "The interests or equities of creditors (liabil-
amples of the previous section? If our ac- ities) are claims against the entity arising from
past activities or events which, in the usual case,
counting criteria for expense and liability require for their satisfaction the expenditure of
recognition were sufficiently precise and corporate resources.... The discharge of a liabil-
complete, we could measure this situation ity at a determinable date is normally required
against the rules and reach an easy an- by contract or intent of parties."8
swer. Unfortunately the criteria in this area Any future tax item arising from the
do not permit so easy an approach. cases of the previous section fails com-
The 1957 Revision of Accounting and pletely to meet these usual tests of a liabil-
Reporting Standards for Corporate Finan- ity. The Federal government recognizes
cial Statements may serve as a guide. It no "claim against the entity" in its record-
says with regard to expenses: keeping; "the expenditure of corporate re-
"Recognition of cost expiration [expense] is sources" will not be required,neither at a
based either on complete or partial decline in the "determinable date" nor at any other
usefulness of assets or the appearance of a liabil-
ity without a corresponding increase in assets....
time.
The issuance of product guarantees, notice of Professor Moonitz, in a sense, assumes
adverse court rulings, and similar events estab- the existence of a liability by saying that
lishing the existence- of liabilities call for the the tax effect producedin one year by dif-
recognition of cost expiration."' ferences in depreciation timing has "an
TirE ACCOUNTINGREVIEW, October, 1957, p. 541. 8 Ibid., p. 542.
unavoidable offsetting tax effect in some Depreciation Provisions of the Tax Law
other year." If the tax were based on in- Unaltered
come generated by individual assets, this The depreciation provisions of the tax
assumption might be justified. Since the code are a part of the law of -the land and
tax is based on taxable income of the en- the law may, of course, be altered by Con-
tity however, there need not be a future gress at any time. However, no substantial
effect for the going concern, as we have indication that Congress feels that the
seen, if the two basic criteria are met. present provisions are too generous and
The comparison with bond liabilities should therefore be altered has come to my
made by Moonitz seems entirely beside attention. In fact, there has been some con-
the point. The liability that is recognized tention that present provisions are not
in most bond issues is made up largely of generous enough and that the amount of
the discounted present value of required acceleration permitted should be increased.
future interest payments. In fact, in the All of the history of tax legislation indi-
example cited of a bond issue that is al- cates that once special rights9 are granted,
ways refunded (a perpetuity, in other it is very difficult and unusual for Congress
words) the present value of the future in- to withdraw them, especially if the return
terest payments is the measure of the en- to the former rules would result in a dou-
tire liability. If it were possible to issue bling-up of tax burdens during the years of
bonds on a perpetual basis at a zero in- return. Current discussions of impending
terest rate, would a liability exist? The tax legislation all make mention of possible
answer clearly would seem to be no, that alterations in tax rates (the Moonitz crite-
such a transaction is in the nature of a rion (a)), but do not hint at less generous
gift. That is precisely the effect produced depreciation methods.
for the going concern by accelerated tax It is this feature of permanence of the
depreciation. So long as the firm follows a depreciation provisions of the tax law and
regular investment policy, it will receive a their general applicability that distin-
"gift" of having its income tax payments guishes cases of the sort under considera-
permanently reduced. It may well be ar- tion from those arising under the 60-month
gued that a gift should not be permitted to amortization provisions of the Revenue
distort comparative operating results by Acts of 1940 and 1950. Under those acts,
reducing an expense, but the solution is to rapid amortization was permitted only for
treat income taxes as an income distribu- facilities for which certificates of necessity
tion rather than to recognize an expense were issued. Even though continuous in-
than simply does not exist. vestment was planned by the firm, there
THE PROBABILITY OF THE NECESSARY
could be no assurance that the new facili-
CONDITIONS BEING REALIZED
ties would qualify for certificates of
necessity. Consequently when depreciation
The preceding sections indicate that charges on the tax return exceeded those
there will be no liability for future taxes shown on the financial statements, an off-
for static or growing firms if depreciation setting tax effect in a future year or years
provisions of the tax laws remain un- was possible if the criteria cited by Moon-
changed (or become more generous) and a itz were likely to be met.10 Where acceler-
regular policy of investment in depreciat-
ing assets is maintained. How likely is it 9 If tax depreciation exceeds book depreciation, this
that these necessary conditions will be is an indication that the firm is enjoying a special right.
10Measurement of the effective present liability,
realized? though, would be a substantial task as the next section