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The Handbook to IFRS Transition and to IFRS U.S. GAAP Dual Reporting by Francesco Bellandi

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2.10 THE IMPACT OF ALTERNATIVE BASES OF REPORTING

2.10.1 Accepted Bases of Accounting for Foreign Private Issuers

Form 20-F includes consolidated financial statements and related notes, under the appropriate comprehensive basis of accounting.161 It also permits cross-referencing to the financial statements for information that is required by a comprehensive basis of accounting.162 In general, foreign private issuers have an option to include financial statements, both on an annual and (when required) on an interim basis, in documents filed with the SEC under different bases of accounting. If foreign private issuers do not use U.S. GAAP, they may include financial statements under IFRSs as issued by the IASB and in accordance with its English version (also referred to as “IASB-IFRSs”). They may also use IFRSs as adopted by the European Commission for use in the European Union (the so-called “EU-GAAP” or EU-IFRSs”), IFRSs as adopted by another jurisdictional version, or another comprehensive basis of accounting (i.e., local or national GAAP). Of course, as Paragraph 7.4.1 following explains, IFRS for small and medium-sized entities is not an option for publicly traded companies, such as SEC registrants or foreign private issuers.

Comment: Form 20-F mentions comprehensive bases of accounting.163 Available options under Form 20-F are IFRSs as issued by the IASB, as well as potentially GAAP other than IFRSs or U.S. GAAP, to the extent they are a comprehensive basis of accounting. ...

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