Cash Flow

New Revenue-Recognition Rules: The Apple of Apple’s Eye?

The computer company and other tech outfits are likely to cash in on revenue-recognition changes if the new regs take on an international flavor.
Marie LeoneSeptember 16, 2009

While Steve Jobs was preparing to introduce the new Apple iPod nano last week, the company’s chief accountant, Betsy Rafael, was sending off a second letter to the Financial Accounting Standards Board related to revenue recognition. At issue: how FASB might rework the rules related to recognizing revenue for software that’s bundled into a product and never sold separately.

The rule is especially important to Apple because it affects the revenue related to two of the company’s most successful products — the iPod and the iPhone. If FASB’s time line holds to form, and the rules are recast in 2010 the way Apple hopes they will be, the company could be able to book revenue faster, yielding less time between product launches and associated revenue gains. In theory, a successful launch — and its attendant revenue — would drive up Apple’s earnings, and possibly stock price, in the same quarter the product is introduced, according to several news reports that came out earlier this week.

Apple and other tech companies have been lobbying for a rewrite of the so-called multiple deliverables, or bundling, rule for quite some time. They argue that current U.S. generally accepted accounting principles make it hard for product makers to reap the full reward of successful products quickly. That’s mainly because U.S. GAAP is stringent about when and how companies recognize revenue generated by software sales.

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“The requirements are that when you sell more than one product or service at one time, you have to break down the total sale value in[to] individual pieces. Establishing the individual values under U.S. GAAP is solely a function of how the company prices those products and services over time,” PricewaterhouseCoopers’s Dean Petracca told CFO in an earlier interview. Contracts typically include such multiple “deliverables” as hardware, software, professional services, maintenance, and support — all of which are valued and accounted for differently.

The complex accounting rule has left many product makers waiting for a chance to voice their displeasure at the standards, and the most recent comment period saw such giants as Xerox, IBM, Dell, and Hewlett-Packard — as well as relative newcomers like Palm and Tivo — make their case to FASB. In all, 34 companies wrote to FASB during the month-long comment period that ended in August to register their opinions on the accounting treatment of multiple elements.

A broader revenue-recognition discussion paper was issued by FASB and the International Accounting Standards Board in December 2008 for a six-month comment period. The boards are currently reviewing the comments, and an exposure draft on revenue recognition, which is the penultimate step to a new global rule, is expected out next year.

Regarding the issue of multiple deliverables, most technology companies would like to see FASB move closer to international standards with regard to bundled software, and drop the requirement for vendor-specific objective evidence. Under GAAP, VSOE of fair value is preferable when available, according to Sal Collemi, a senior manager at accounting and audit firm Rothstein Kass.

Basically, VSOE is equivalent to the price charged by the vendor when a deliverable is sold separately — or if not sold separately, the price established by management for a separate transaction that is not likely to change, explains Collemi.  Third-party evidence of fair value, such as prices charged by competitors, is acceptable if vendor-specific evidence is unavailable. Many technology companies argue that it is sometimes impossible to measure the fair value of a component that is not sold separately, but rather is an integral part of the product — as is the Apple software for the iPod series of products.

At the same time, international financial reporting standards require companies to use the price regularly charged when an item is sold as the best evidence of fair value. The alternative approach, under IFRS, is the cost-plus margin, says Collemi. That is, the IFRS puts the onus on management to value a product component based on what it costs to manufacture the piece plus the profit-margin share built into the item. Management usually bases its valuation on historic sales as well as current market-established sale prices. The cost-plus margin is not allowed under GAAP.

With respect to bundled components, the IFRS focuses on “the substance of the transaction and the thought process and ingredients that go into the transaction,” contends Collemi, who says the standard’s objective is to make economic sense out of the transaction. FASB’s take on the subject is more conservative: the U.S. rule maker calls for objective evidence to establish value.

Some critics say the IFRS approach invites abuse, because it’s based on management assumptions. But Collemi contends that GAAP accounting is filled with rules and interpretations that require management estimates, and that the burden is on management to produce the correct numbers. What’s more, auditors are in place to act as a backstop to verify the processes used to arrive at management estimates. “If management is following the spirit of the transaction and doing the right thing,” adds Collemi, “then it is up to auditors to challenge the estimates.”