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    GAAP Arbitrage: Valuation Opportunities in International Accounting StandardsAuthor(s): Lawrence S. Speidell and Vinod B. BavishiSource: Financial Analysts Journal, Vol. 48, No. 6 (Nov. - Dec., 1992), pp. 58-66Published by: CFA InstituteStable URL: http://www.jstor.org/stable/4479597 .

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    GAAP

    Arbitrage:

    Valuation

    Opportunities

    in

    International

    Accounting

    Standards

    Lawrence S. Speideli

    and

    Vinod

    B. Bavishi

    Accounting

    standards

    diffler

    greatly

    across countries.

    But the

    differences

    can

    present opportunities

    for

    those able

    and willing to

    make

    the

    effort

    to under-

    stand and adjust

    for them.

    In a recent project,

    the ac-

    counting

    statments

    of

    over

    100 companies in

    12

    devel-

    oped and emerging

    coun-

    tries were restated

    to ap-

    proximate

    common

    accounting

    standards.

    Companies in Sweden and

    Germany

    showed

    the

    big-

    gest gains

    from

    restatement.

    On

    average,

    these

    compa-

    nies' net incomes increased

    by

    60%

    and

    44%, respec-

    tively,

    while shareholders'

    equity

    increased by

    44%

    and

    41%.

    A

    good

    plan, violently

    exe-

    cuted

    right

    now is far better

    than

    a

    perfect plan

    executed

    next week.

    General

    George

    Patton

    Shareholders, corporations and

    governments

    depend

    more

    heavily

    now than ever before

    on

    accurate and

    comparable global

    financial data. Shareholders,

    the

    traditional clients

    of financial re-

    ports,

    have become much more

    numerous

    and widespread.

    The global equity

    markets now

    total over

    $12

    trillion, compared

    with

    $2.7

    trillion

    in

    1980.

    And the

    flow of cross-border

    equity

    in-

    vesting,

    now over

    $1.2

    trillion,

    is

    expected to

    grow

    to $2.5 billion

    by the

    mid-1990s

    and $13

    trillion

    in 20 years.

    In

    the

    U.S.

    alone,

    institutional

    investors

    are 6%

    in-

    vested

    abroad

    and will shortly

    be

    moving

    to 10%

    and more.

    Figure

    A illustrates

    the current

    world of

    equity

    markets,

    repre-

    sented by

    size. The

    map

    will

    change

    as equity

    capital

    markets

    grow in the newly capitalistcoun-

    tries of

    Eastern Europe

    and

    Asia.

    Corporations

    have

    historically

    cared

    more about

    internal than

    external reporting.

    But as product

    markets are

    becoming

    more glo-

    bal,

    merger

    activity

    has

    increased,

    with

    companies

    combining

    across country

    borders and

    across accounting

    borders.

    Cross-

    border mergers

    and

    acquisitions

    have accounted

    for

    over $200

    bil-

    lion

    annually, stimulated

    by

    changes

    in the European

    Com-

    munity

    and

    the raising

    of

    the Iron

    Curtain.

    Governments

    have

    responded

    to

    the

    economic

    imperative

    of

    capi-

    talism

    and are

    scrapping

    the

    cen-

    tral planning

    of communist

    and

    socialist

    regimes.

    They

    all want

    to

    fulfill

    the dreams

    of their

    people

    and

    to become

    the next Japan,

    Korea or Taiwan. This cannot

    happen

    if capital

    is

    allocated

    sim-

    ply where

    financial

    reports are

    clearest,

    rather

    than

    where

    costs

    are

    lowest or profit

    opportunities

    highest.

    The objective

    of

    an efficient

    glo-

    bal capital

    market

    faces

    a

    major

    obstacle

    in

    the labyrinth

    of

    com-

    plex

    and obscure

    accounting

    practices

    prevalent

    around

    the

    Figure

    A

    1990 Market Capitalizations

    of Developed and Emerging

    Markets

    (millions

    of U.S. dollars)

    Daen

    Nsr

    and

    o

    PlandJ

    Lnited Hunnt,

    /

    BrItinm'' H

    gary

    tates

    D'lvoire

    Ca

    hnslNeakia

    Tnda

    4J5Aaeca

    XBSt~ ~ ~ ~ ~~~Btsaa

    Tnbago

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    LU

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    60

    History of GAAP

    Through he years, ocal practitio-

    ners have developed

    accounting

    standards primarily

    to fill

    the

    needs of local

    commerce. Gov-

    ernmentshave stepped

    n

    to con-

    trol accounting or tax purposes.

    The result is a patchwork f sys-

    tems with differing theoretical

    and conceptualfoundations.

    Fig-

    ure

    B

    diagrams

    hese as a

    family

    tree with two principalbranches-

    micro-based,

    company-level

    ac-

    counting,

    romwhich the U.S.and

    U.K. systems are derived, and

    macro-based,

    government-im-

    posed systems,

    often

    heavily

    in-

    fluenced

    by

    tax

    policies,

    which

    prevail throughout

    most of Eu-

    rope.

    Table

    II

    Consolidation

    Pracdces,

    1990

    No Consolidation

    India

    All Subsidiaries Consolidated

    Canada

    Mexico

    United States

    Argentina

    Brazil

    Chile

    Venezuela

    Austria

    Belgium

    Denmark

    Finland

    France

    Germany

    Italy

    Netherlands

    Norway

    Spain

    Sweden

    Switzerland

    United

    Kingdom

    South Africa

    Hong Kong

    Malaysia

    Singapore

    Thailand

    Australia

    New Zealand

    Domestic

    Consolidation,

    Others at

    Cost

    Japan

    Korea

    Domestic Consolidation, Others at

    Equity

    Taiwan

    Source:Cfarbase.

    Table Im Long-Tern Investments

    (20%-50% owned),

    1990

    Equity Method

    Canada

    United

    States

    Brazil

    France

    Netherlands

    United Kingdom

    South Africa

    Taiwan

    New Zealand

    Cost

    Method

    Austria

    Belgium

    Germany

    India

    Pakistan

    Thailand

    Cost

    and/or Equity Method

    Mexico

    Chile

    Venezuela

    Denmark

    Finland

    Italy

    Norway

    Portugal

    Spain

    Sweden

    Switzerland

    Hong Kong

    Japan

    Korea

    Malaysia

    Singapore

    Equity

    Method but

    Partially

    Consolidated

    Australia

    Source: Cfarbase.

    Both

    the

    U.S.

    and the U.K.

    systems

    have spawned siblings

    in

    related

    countries. U.S. GAAP

    has a

    heavy

    influence

    in

    Canada, Japan, the

    Philippines

    and

    Mexico,

    while the

    U.K.

    system

    has

    prevailed

    in

    many

    of the Commonwealth countries.

    Within

    these broad

    groups,

    how-

    ever, there remain many differ-

    ences

    resulting

    from

    strong

    na-

    tional

    professional groups.

    Despite our

    desire for

    compara-

    bility

    in

    global accounting,

    there

    would be no net

    gain

    if

    compara-

    bility required undermining

    the

    vitality

    of these national account-

    ing

    organizations.

    Furthermore,

    total comparabilitydoes not

    seem

    likely in the near

    fulture,

    iven the

    vigorous debate at recent ses-

    sions of the

    international odies.

    It is thus important or users of

    globalfinancial tatements

    o

    turn

    from

    complaints o analysis,and

    to view

    global accounting

    differ-

    ences as an opportunity

    o

    profit

    from careful

    reconciliation.

    Philosophical

    Differences

    Differences

    n

    philosophyacross

    accountingregimes

    are

    often

    in-

    tractable,

    because often there

    is

    simply

    no

    right

    answer.Alterna-

    tives exist because different

    points of

    view can

    be equally

    valid.Globalcommerce mayone

    day produce

    a

    consensus,but

    for

    now that

    outcome s as unlikelyas

    havingautomobilesdrive on the

    right side of every nation'shigh-ways.Usersmustbe made aware

    of these differences and must

    Table

    IV

    Inventory Valuation

    Method, 1990

    Mixed

    Canada

    United States

    Chile

    Austria

    Belgium

    France

    Germany

    Italy

    Switzerland

    Japan

    Korea

    Average

    Cost Method

    Mexico

    Brazil

    Spain

    Hong Kong

    Malaysia

    Pakistan

    Singapore

    Taiwan

    First-In-First-Out Method

    (FIFO)

    Denmark

    Finland

    Netherlands

    Norway

    Sweden

    United

    Kingdom

    South Africa

    India

    Thailand

    Australia

    New Zealand

    Last-In-First-Out Method

    (LIFO)

    Venezuela

    Source: Cfarbase.

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    Table V

    Depreciation

    Method,

    1990

    Straight-Line

    Method

    Canada

    Mexico

    United

    States

    Argentina

    Brazil

    Chile

    Venezuela

    Belgium

    Denmark

    France

    Italy

    Netherlands

    Portugal

    Spain

    Switzerland

    United

    Kingdom

    South

    Africa

    Hong

    Kong

    India

    Malaysia

    Pakistan

    Singapore

    Taiwan

    Thailand

    Australia

    New

    Zealand

    Accelerated

    Method

    Sweden

    Japan

    Korea

    Straight-Line

    and/or

    Accelerated

    Method

    Finland

    Germany

    Norway

    Source:

    Cfarbase.

    Table

    VI

    Frequency

    of

    Interim

    Financial

    Statements,

    1990

    Two

    Per Year

    France

    Germany

    Spain

    Switzerland

    United

    Kingdom

    Japan

    South

    Korea

    Three Per

    Year

    Norway

    Four

    Per Year

    Canada

    Mexico

    United

    States

    Source:

    nternational

    Accounting

    and

    Audit-

    ing

    Trends, 2nd

    ed.

    Figure D Classification of Companies by Year-End Dates, Fiscal Year

    1990

    100

    -1

    I

    Australia 138

    Companies

    80

    7

    9

    Canada-

    315

    Companies

    72

    6 Japan 2,692 Companies

    60 -

    *

    United Kingdom

    549

    Companieso -

    ~~~~~~~~~~~~~~~~

    2 _United

    States

    2,919 Companies

    47

    40 -

    28

    201

    -

    14

    1

    1

    7

    16

    14

    14

    15t

    0

    -

    1 , 1 11

    January

    -

    March April

    -

    June July

    -

    September October

    -

    December

    X,

    of

    Companies

    with Year-End

    Dates Between

    Source:Cfarbase.

    make

    their best

    effort

    to

    adjustfor

    them.

    Major

    philosophical

    differ-

    ences

    include

    the

    following.

    Cost

    Basis of

    Financial

    State-

    ments:

    While historical

    cost

    was

    hardly

    questioned 20

    years

    ago, it

    Figure E Business

    Segment Data

    Australia

    76

    82

    59

    Canada

    63

    82

    France

    6

    28

    U

    Assets

    Germany 2

    Income

    41

    Sales

    Japan

    2

    60

    79

    Singapore

    93

    88

    13

    U.K.

    72

    80

    l I

    l

    I

    0

    20 40

    60 80

    100

    % Disclosure

    Source:Cfarbase.

    tN

    14

    LL

    0)

    LU

    LU

    0

    cl

    z

    z

    J

    0

    U

    I,::

    z

    -

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    z

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    61

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    Figure F

    Percentage of Companies Audited by Leading Accounting

    Firms

    U.S.

    98%

    Italy

    97%

    Chile

    96%

    U.K.

    94%

    Japan

    88%

    Germany

    87%

    Spain

    80

    Mexico

    69%

    Belgium

    69%

    Switzerland

    65%

    France

    58%

    Brazil

    50%

    India

    27%

    Israel ox

    7~~~~~ I j# 'g

    I

    0 20 40 60 80 100

    Source:nternational

    Accounting

    nd

    Auditing

    Treds,

    2nd

    edition.

    is the sole basis today

    mainly in

    the

    U.S.,

    Japan,Germany,Canada,

    Switzerland,

    Austriaand South

    Af-

    rica. As

    Table

    I

    shows, adjust-

    ments for inflation are

    now com-

    mon elsewhere.

    Consolidation

    Practices: Signifi-

    cant corporate activities are often

    missing from

    company reports

    because

    of

    a

    failure to

    provide

    consolidated

    statements. This is a

    significant problem for

    financial

    statement users

    in

    Japan,

    Korea

    and Taiwan (see Table lI).

    Accountingfor Long-Term

    Invest-

    ments: The pattern of accounting

    for investments of 20% to 50% of

    equity

    is similar to that for con-

    solidation of

    majority-owned

    sub-

    sidiaries, as Table ILLhows. Only

    in

    a few

    countries,

    including the

    U.S.,

    the

    U.K., Canada,

    Singapore

    and

    Australia,

    can one expect all

    tcontrol nterests to be fully re-

    flected

    in the income

    stream.

    Elsewhere

    (most notably in Ger-

    many),

    these

    positions

    are ac-

    counted

    for on a cost basis,

    with

    only dividends

    recognized

    in

    in-

    come.

    In

    Japan,

    where

    accounting

    for

    both

    majority

    and

    minority

    inter-

    ests varies widely, comparative

    analysis

    of

    companies

    is ex-

    tremely complex

    because

    of the

    popularity of cross-holdings.

    These

    are the foundation

    of the

    powerful

    cooperative

    company

    groups

    known as keiretsu.

    The

    organization

    chart

    of the Tokyo

    Group,

    for

    example,

    looks like

    the web of a drunken

    spider and

    includes

    334

    firms with interests

    in

    railroads,

    hotels,

    construction,

    Table

    VII

    Availability

    of English-

    Langugage

    Financial

    Statements,

    1990

    AlU Conpanies Report in English

    Canada

    United States

    United

    Kingdom

    South

    Africa

    Hong Kong

    India

    Malaysia

    Pakistan

    Singapore

    Australia

    New Zealand

    More than

    40% Report in English

    Chile

    Venezuela

    Belgium

    Denmark

    Finland

    Netherlands

    Norway

    Portugal

    Spain

    Sweden

    Switzerland

    Japan

    Taiwan

    Thailand

    Less than 40% Report

    in

    England

    Mexico

    Argentina

    Brazil

    Austria

    France

    Germany

    Italy

    Korea

    Source: Cfarbase.

    Figure G Percentage of

    Analysts

    in

    Agreement

    on Last

    Year'sEPS

    Canada

    100

    %

    japan

    100%

    U.K.

    100%

    U.S.

    100%

    Germany 99%

    France

    96%

    Spain

    88%

    Italy

    84%

    Switzerland

    79%

    0

    20 40

    60

    SO

    100

    Source:

    /BIE/S.

    UJ

    LLI

    LU

    z

    D

    -J

    z

    -J

    z

    6

    62

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    Figure

    H Adjusted versus Reported

    Income

    Sweden

    _ _

    ______60_

    2

    26~~~~~4

    Germany

    28

    Japan

    1

    Italy

    Belgium

    9

    France

    6

    Net

    Income

    Australia

    =

    r 5

    1

    - Operating

    ncome

    U.K.

    Switzerland

    -8

    -10 0 10 20 30 40 50 60 70

    %

    Change

    airlines and retail. This

    complex-

    ity recently increased

    when the

    group established an

    antitakeover

    plan

    under which 35% of each

    listed

    company would be held by

    other

    group

    members.

    Inventory-Valuation Methods: As

    Table IVshows, these

    vary widely,

    with first-in, first-out

    used

    in

    the

    U.K. and Scandinavia, while aver-

    age cost is used

    nearly every-

    where

    else. Recently,controversy

    increased when the

    IASC indi-

    cated its

    disapproval

    of

    last-in,

    first-out

    accounting,

    a

    popular al-

    ternative

    in

    the U.S.

    Depreciation: Depreciation meth-

    ods

    cause some of the most dra-

    matic comparability

    problems for

    global investors. While

    most U.S.

    investors expect to see

    straight-

    line

    depreciation, accelerated de-

    preciation, which tends to under-

    state

    earnings,

    is

    most

    popular

    in

    Japan

    and Korea.

    Meanwhile,

    ex-

    cess

    (often

    arbitrary) deprecia-

    tion

    charges

    are sometimes used

    to smooth

    earnings

    in

    continental

    Europe

    (see Table V).

    Quality

    Differences

    While the many

    philosophical dif-

    ferences can be

    subject

    to

    endless

    debate,

    quality

    differences can-

    not.

    High-quality accounting is

    imperative, and anything less

    costs

    companies dearly

    in

    lower

    stock

    prices and higher capital

    costs. The world standard should

    be

    full, prompt and reliable dis-

    closure, and

    in

    this

    respect, many

    nations fall short.

    Timeliness: There is no justifica-

    tion for a delay of over six months

    in

    availability of annual reports,

    when most U.S.

    and

    U.K.compa-

    nies deliver them

    in

    three

    months. Surprisingly, Germany,

    France and Italy are

    among the

    worst offenders in

    this regard

    (see Figure C).

    Interim Statements:

    While quar-

    terly reports are the

    standard

    in

    the

    U.S.,

    Canada and

    Mexico,

    most companies

    in

    other coun-

    tries provide only semiannual

    data

    (Table VI).

    Comparisons

    quickly

    lose

    validity

    when based

    on

    old data. This problem be-

    comes particularly

    important

    when fiscal-year dates

    differ; this

    is the case when

    comparing most

    Japanese companies,

    which use a

    Marchfiscal year, with those else-

    where (see Figure D).

    Segment

    Disclosure:

    In

    the

    U.S.,

    the Financial

    Accounting

    Stan-

    dards Board

    mandated

    business-

    segment

    disclosure with State-

    ment 16

    in

    1976.

    Elsewhere

    many

    companies

    have

    voluntarily

    made

    this disclosure.

    As

    Figure

    E

    shows, however,

    coverage

    is still

    spotty.

    Leading Accounting

    Firms:While

    many small firms do

    excellent

    work, their

    independence is

    sometimes subject to question.

    Figure I

    Adjusted

    versus

    Reported

    Book

    Value

    Sweden

    44

    Germany

    41

    Japan

    14

    Switzerland

    4

    Australia l

    U.K.

    -14

    Belgium

    -14

    France

    -28

    Italy -28

    I

    I

    II

    -40

    -30 -20

    -10

    0

    10

    20

    30 40

    50

    %

    Change

    LUl

    m

    0)

    LLU

    LU

    D

    UJ

    0

    z

    U

    z

    z

    63

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    Figure J Adjusted versus Reported Price/Earnings

    Ratio

    Australia

    124.1

    9

    ReportedP/E

    France

    12.6

    11.4

    Adjusted P/E

    Germany

    26.5

    71.I

    Japan

    1

    451

    Switzerland

    12.7

    U.K. 1(1.5|

    9.5

    0 10

    20

    30

    40 50 60

    70

    80

    The leading

    accounting

    firms up-

    hold

    a

    high

    standard,but

    smaller

    firms, particularly in emerging

    markets (such

    as India)

    may be

    heavily

    influenced

    by

    their cli-

    ents. Figure

    F

    shows

    the

    percent-

    age

    of various

    countries'

    firms

    audited by large accounting

    firms.

    Earnings

    Per Share:

    An example

    of

    improvement

    in

    comparability

    is

    shown in Figure

    G, which

    re-

    flects

    the influence

    of

    I/B/E/S

    (the

    Institutional

    Brokers Estimate

    System)

    on

    financial

    analysts'

    be-

    havior. I/B/E/S

    has been

    collect-

    ing Wall Street

    brokers' earnings

    estimates

    for

    U.S. companies

    since 1971,

    but

    it only began

    col-

    lecting

    abroad

    in

    1986. At

    that

    time,

    analysts

    often

    could not

    agree

    on

    what

    companies

    had

    earned

    in

    the

    prior

    year,

    let alone

    their estimate

    for

    the future.

    To-

    day,

    the

    situation

    is

    much

    im-

    proved,

    although

    it is still

    weak

    in

    southern Europe.

    Language:

    While it may seem

    ar-

    rogant or lazy on

    the part

    of

    En-

    glish-speaking

    people to

    expect

    financial statements in English,

    our

    language

    has

    become a stan-

    dard

    for business

    around

    the

    world. Already,

    many

    companies

    publish

    English language

    annual

    reports (see

    Table

    VII).

    We

    hope

    to see

    the

    percentage

    increase,

    particularly

    in

    continental

    Eu-

    rope. Users

    must be

    careful,

    how-

    ever,

    because there

    is often more

    detail

    in

    the local language

    re-

    ports.

    Accounting

    Adjustments

    In the art world,

    it is

    sometimes

    said that a piece is never com-

    pleted,

    the artist

    has simply

    stopped

    workingon it for

    a while.

    So too

    in

    accounting.

    Financial

    statements

    are never

    complete or

    perfect,

    they

    are simply

    a best

    guess at

    a given point

    in

    time.

    History

    will judge them

    to

    have

    been

    close

    or otherwise,

    but

    it

    will

    rarely

    find them

    perfect.

    This

    simplifies the

    task of adjustment;

    to achieve significant

    gains

    in

    glo-

    bal

    comparability,

    we

    need

    not

    strive for

    absolute precision.

    We analyzed

    over

    100 companies

    from

    12 countries

    and five

    broad

    industrygroups

    (consumer

    goods,

    capital goods,

    basic

    industries,

    utilities

    and transportation).

    These

    companies

    were

    selected

    from the 900

    largest global

    com-

    panies

    ranked by

    sales,

    assets and

    market capitalization.

    Using a spreadsheet

    template,

    ad-

    justments

    were make

    to standard-

    ize accounting

    for depreciation,

    non-equity

    and discretionary

    re-

    serves, goodwill,

    consolidation,

    valuation

    of investment,

    asset

    re-

    valuation, inventory adjustments,

    intercompany

    transactions,

    for-

    eign currency

    translation,

    ex-

    traordinary

    items

    and deferred

    taxes.

    The appendix

    describes

    the

    adjustments

    for one company,

    Bayer

    AG.

    Aftermaking

    our

    adjustments,

    we

    calculated

    the

    net changes

    in

    the

    income statement,

    balance

    sheet

    and

    ratios

    such as

    P/E

    and

    price/

    book. Thirty-six

    companies

    with

    extreme

    changes

    were eliminated

    to produce

    summary

    data for 83

    companies.

    The changes

    of greatest

    signifi-

    cance

    for

    valuation may

    be

    those

    affecting

    the

    income statement.

    Figure

    H

    summarizes

    the direc-

    tion and magnitude

    of

    changes

    in

    operating

    income

    and net income

    by

    country (using

    the equal-

    weighted

    average).

    When ad-

    justed

    to

    a uniform global

    stan-

    dard,

    Sweden

    and Germany

    show

    the

    greatest

    gains,

    with

    net

    in-

    come

    increases

    of 60%

    and

    44%,

    respectively. Next come Japan,It-

    aly

    and Belgium

    with

    gains

    of

    12%,11% and

    4%. Only

    Switzer-

    land showed

    a decline.

    There

    were

    also significant

    changes

    on

    the

    balance

    sheet,

    shown

    in

    Figure

    I.

    Again,

    Sweden

    and Germany

    were

    big

    gainers,

    with

    increases

    of

    44% and

    41%

    in

    Figure

    K

    Adjusted

    versus

    Reported

    Price/Book

    Value

    Ratio

    Australia

    16

    2.(4

    France

    2.32

    _3.25~~~~~~~~~~~~~~~~~~~~~~~~~~~~.

    Germany

    1

    1.61

    ~~~~~~~~~~~~~~~~~~~~~~~~

    1.1

    Japan

    _ _ _

    _2.GI_3.18

    Switzerland

    2._17_Reported

    P/BV

    1.9.3

    2.2()0

    Adjusted

    P/BV

    U.K.

    2.30_

    0.0

    1.0

    2.0

    4.0

    L1J

    m

    0:

    LU

    z

    64

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  • 8/15/2019 GAAP Arbitrage

    9/10

    shareholders' equity.

    At

    the

    other

    extreme,

    French and Italian

    com-

    panies had a 28% reduction

    in

    equity.

    Figures J and

    K

    show the changes

    in P/E and price/book for these

    markets when going from re-

    ported

    to

    adjusted

    bases.

    Conclusion

    We

    adjusted

    standards toward the

    U.S/U.K. conventions. This re-

    sulted

    in

    large changes

    in

    Ger-

    man, Japanese,

    Swedish

    and

    Swiss

    reported figures. Regardless of

    the norm

    chosen, however,

    those

    countries appear

    to

    understate

    values by amounts that are some-

    times

    very significant.

    Furthermore, there is evidence

    that capital

    markets are not mak-

    ing a complete reconciliation for

    these differences. Over

    time

    they

    will, as analysts make more com-

    plete adjustments and as accoun-

    tants make

    progress

    toward

    glo-

    bal standards.

    As this

    occurs,

    capital

    markets

    will

    become more

    efficient,

    and

    financial

    rewards

    will

    accrue to those investors who

    anticipate

    the

    direction of

    changes

    in

    valuation.

    Meanwhile,

    it

    is the responsibility

    of

    investors

    and all other users of financial

    statements to

    press

    for

    improved

    global accounting,

    based on full

    disclosure,

    so

    philosophical

    dif-

    ferences can be

    reconciled,

    and

    on the standard

    of

    uniform

    high

    quality

    around

    the world.

    Appendix

    Bayer Restatement

    Table

    AI

    shows the accounting

    restatement for Bayer. The single

    most significant factor in the re-

    statement is

    depreciation

    ex-

    pense.

    This is true for

    many

    other

    German

    companies.

    The

    method allowed by regula-

    tion

    is

    the

    declining-balance

    method until the

    depreciation by

    the straight-line method is

    greater. The straight-line method

    is used from that point. Also, de-

    preciation computed using the

    declining-balance method cannot

    exceed three times the amount

    computed using the straight-line

    method

    in

    any given year (i.e.,

    depreciationcharged during

    the

    year

    is limited to three

    times the

    straight-line epreciation, egard-

    less of the method used).

    Basedon the rules above,an asset

    with a 30-year ife will be fully

    depreciated

    in

    approximately

    nine years. Because the majority

    of

    assetsare depreciated

    n

    such a

    shortperiod,

    the

    measurement

    f

    the

    actual ife

    of

    assets s difficult.

    One

    can

    use

    the

    averagedepreci-

    ation

    expense

    to sales or cost of

    goods

    sold

    of a

    similar

    company

    for estimation.

    For

    example,

    Wella

    AG

    in

    Germanyprovides

    depreciation expenses

    on the

    straight-linemethod (although ts

    size is about6%

    of

    Bayer's).Table

    All compares Bayer and Wella.

    After the adjustments o Bayer,

    accumulated depreciation as a

    percentage

    f

    adjusted

    otal

    assets

    is similar to Wella, at 28%, but

    depreciation expense as

    a

    per-

    centage

    of sales is still

    higher,

    at

    4%,compared

    with

    Wella's2.6%.

    Alternatively,one can assume

    Bayer's perating tructures sim-

    ilar to thatof other multinational

    corporations n the same indus-

    try.The averagedepreciation x-

    pense for these major multina-

    tional corporations

    can then

    be

    used as an approximationor Bay-

    er's.TableAIII llustrates he

    pro-

    Table AI Accounting Restatement for German Multinational

    ChemicalCompanyBAYER G For FiscalYearending on

    December

    31, 1990 (in

    millions

    of

    DM)

    1. Operating Income

    As Reported

    +

    Add back excess depreciation

    =

    Adjusted Change

    3,551

    +

    1,341 = 4,892 +38%

    2.

    Shareholders' Equity

    *

    Add back cumulative effect of excess depreciation after tax

    *

    Add back special non-equity reserves

    As Reported

    +

    Adjustments

    =

    Adjusted Change

    15,545 6,795

    =

    22,340 44%

    3. Price/EarningsRatio

    Will reduce from 7.2 to 5.6 (22% reduction)

    4. Price/Book Ratio

    Will reduce from

    0.9

    to 0.6

    (32% reduction)

    Table All Adjustment for

    Depreciation, Method

    1

    (fiscal year

    1990)

    Bayer

    Wella

    Sales

    41,643.000

    2,562.000

    Total Operating Expenses

    38,092.002 2,435.000

    Total Assets 37,947.000 1,728.000

    Gross Fixed Assets

    43,800.000

    762.000

    Depreciation Unadjusted

    3,034.000 67.000

    (% of Sales)

    7.29% 2.62%

    Depreciation Exp. Adjusted

    1693.000 67.000

    (%

    of

    Sales) 4.00%

    2.62%

    Depreciation Method Tax Rules

    Straight

    ine

    Accumulated

    Dep. Unadj. 29,841.000

    394.000

    (%

    of

    Total

    Assets)

    78.64% 22.80%

    (% of Gross Fixed

    Asset) 68.13%

    51.71%

    Adjusted Total Assets

    53,013.000

    Accum. Dep. Adj.

    14,775.000

    (%

    of

    Adj.

    Total

    Assets) 27.87%

    (N

    a,

    a,

    LU

    LUS

    z

    z

    D

    0

    -J

    65

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  • 8/15/2019 GAAP Arbitrage

    10/10

    Table AIII Adjustment or

    Depreciation,

    Method

    2

    Bayer

    ICI

    Sandoz

    Ciba-Geigy

    Sales

    in

    U.S. Dollars

    27,900.810

    24,521.400

    9,650.000

    15,360.000

    Pharmaceutical% Sales

    19% 11%

    46% 32%

    Dep. Method

    Tax Rules SL

    Method SL

    Method

    Depr. CurrentValue

    Unadj.

    Dep. Exp. % Sales

    7.30% 4.10%

    5.80%

    5.50%

    Adj. Dep. % Sales 4.00%

    Accum. Dep. % Assets

    Unadj.

    78.60% 43.00%

    20.40% N/A

    Accum.

    Dep. % Assets Adj.

    27.87

    cedure.

    One drawback o this

    ap-

    proach is

    that it raises

    cyclical

    issues in

    evaluating

    companies

    that

    are exposed to differing

    co-

    nomic

    conditions in

    different

    countries.

    Non-equity reserves

    are also a

    problem in

    restating Bayer ac-

    counting figures.Some types of

    reservesareclearly

    specifiedand

    can

    be easily

    restated.

    However,

    reservesare

    sometimes

    mixed to-

    gether

    and

    not

    clearly specified.

    At Bayer, for

    example,

    reserves

    for future

    uncertain

    business risk

    are

    mixed

    with

    reserves

    or vaca-

    tion and bonus.

    Some estimates

    must be

    made to

    restate

    these reserves.

    One ap-

    proach

    s to estimate

    certainparts

    of

    operating

    reserves.

    Reserves

    for vacation, or example,can be

    estimated from

    companies

    in

    neighboringcountries

    with simi-

    lar cultures.These

    estimated

    op-

    eratingreserves can

    then

    be de-

    ducted

    from

    mixed

    provisions

    and

    the remaindercan be

    added

    back to income.

    an'

    a:'

    uJ

    Ull

    0)

    LUJ

    U

    0

    z

    z

    D

    -

    -J

    lit

    a

    z

    U

    z

    z

    :6

    0

    L/)

    V6

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