IFRS Institute Webcast on Consolidation 052913 Institute Webcast … · 5/29/2013 1 IFRS Institute...
Transcript of IFRS Institute Webcast on Consolidation 052913 Institute Webcast … · 5/29/2013 1 IFRS Institute...
5/29/2013
1
IFRS Institute Webcast
New IFRS Requirements for Consolidation
May 29, 2013
Administrative
CPE regulations require online participants take part in online questions. Participants are required to respond to a minimum of four questions in order to be eligible for CPE credit.
Results will be reviewed in aggregate and may be published as a “pulse survey” of the marketplace in the aggregate. Please note that no responses will be tracked back to any individual or organization.
Send questions via the “Ask a Question” button.
Help Desk: 1-877-398-1471 or outside the United States at 1-954-969-3342
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
11
5/29/2013
2
Today’s presenters
Paul MunterU.S. IFRS Professional Practice Leader KPMG LLP New York
Mike HallAdvisory Partner KPMG LLP New York
John Nabial
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
2
John NabialVice President – Financial Reporting Sumitomo Corporation., U.S.
Learning objectives
By completing this module, you should beable to:
1) Understand the overall impact of the “new suite” of consolidation standards under IFRS
2) Explain the key principles including an understanding of selected application examples when applying the consolidation model under IFRS 10
3) Understand the transition provisions under IFRS 10
4) Understand key differences between U.S. GAAP and IFRS regarding consolidation.
5/29/2013
3
A new suite of consolidation standards
Accounting
IFRS 10
Disclosure Separate FS
IFRS 11 Joint
Associates
Joint ventures
SubsidiariesIFRS 10
Consolidated Financial Statements
IAS 28 Investments
in Associates and Joint Ventures
IFRS 12 Disclosure
of Interests in Other Entities
IAS 27 Separate Financial
Statements
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
4
IFRS 11 Joint ArrangementsJoint operations
Unconsolidated structured
entities
Other Entities
IFRS 11 Joint Arrangements
IFRS 12 Disclosure
of Interests in Other Entities
From IAS 27/SIC-12 to IFRS 10
2008 standards
IFRS 10
Exemptions from preparing consolidated financial
statementsSimilar requirements
Determination of investees to be consolidated
IAS 27 control model New single
control modelSIC-12
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
5
Consolidation procedures Similar requirements
SIC 12 R&R model
5/29/2013
4
Knowledge check 1
Which of the following statements is correct?
A. IFRS 10 provides new guidance for reporting entities regarding investments it controls and over which it exercises significant influence.g
B. IFRS 10 contains accounting and disclosure guidance.
C. IFRS 10 supersedes IAS 27 in its entirety once adopted.
D. IFRS 10 introduces a single control model for purposes of evaluating whether or not an investment should be consolidated.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
6
Knowledge check 1 – Debrief: Correct answer is D
A. Incorrect
B. Incorrect
C. Incorrect
D.Correct, IFRS 10 introduces a single control model for purposes of evaluating whether or not an investment should be consolidated.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
7
5/29/2013
5
IFRS 10 consolidated financial statements in a nutshell
PowerExposure to variability
Link between power andControl + +=
To have power, it is necessary for investor to have existing rights that give it current ability to direct the activities that significantly affect the investee’s returns,
i.e., the relevant activities
Power variability in returns
power and returns
Control + +=
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
8
Control assessed on continuous basis
The new single control model
1 Identify the investee (legal entity or silo)
2 Identify the relevant activities of the investee
3 Identify how decisions about the relevant activities are made
4 Assess whether the investor has power over the relevant activities
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
9
5 Assess whether the investor is exposed to variability in returns
6 Assess whether there is a link between power and returns
5/29/2013
6
Knowledge check 2
Which of the following is a correct statement regarding the six-step approach as outlined on the previous slide?
A. These six steps are specifically included in IFRS 10 and have to be p p yapplied when implementing IFRS 10.
B. These six steps are specifically included in IFRS 10 but reporting entities have an option whether to apply them.
C.Following these six steps will ensure conclusions between U.S. GAAP and IFRS will be the same.
D.These six steps are not specifically included in IFRS 10 but have been
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
10
p p ydeveloped by KPMG as a framework of how an evaluation of an investment could be approached in order to conclude whether or not a reporting entity should consolidate the investment.
Knowledge check 2 – Debrief: Correct answer is D
A. Incorrect
B. Incorrect
C. Incorrect
D.Correct, these six steps are not specifically included in IFRS 10 but have been developed by KPMG as a framework of how an evaluation of an investment could be approached in order to conclude whether or not it should be consolidated.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
11
5/29/2013
7
Identify investee (legal entity or silo)
Control by investor generally assessed at entity level, but also can be assessed over only specified assets and liabilities
(a silo)
1
Silo = portion of an entity
treated as a deemed separate
In substance, assets, liabilities, and equity are separate from overall investee such that none of the assets can be used to pay other obligations of the entity and they are the only source of payment for specified liabilities of the silo
Parties other than those with the specified liability
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
12
separate entity
Parties other than those with the specified liability have no rights or obligations related to the specified assets or to the residual cash flows of those assets
Identify relevant activities of investee 2
Relevant activities = activities that significantly affect the investee’s returns
A range of operating and fi i ti iti
There are different relevantti iti ( hi h
Relevant activities occur l h ti lfinancing activities
significantly affects returns
Determine which of these activities most significantly
affects returns
activities (which can occur at different times)
only when particular circumstances or events
occur (direction of activities predetermined
until this date)
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
13
Assessment of power made at investee’s level
Assessment of power made at this activity’s
level
Only decisions when those events occur
relevant for assessment of power
5/29/2013
8
Identify how decisions about relevant activities are made 3
Are voting rights relevant in assessing whether investor has power over investee?
Gating
Focus on which investor has voting
Investee controlled by means of voting rights
question
Number of factors relevant in assessing
More complex cases
Focus on rights other
Investees designed so that voting rights not relevant
(generally structured entities)
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
14
rights sufficient to direct investee’s
relevant activities
relevant in assessing what is determinative in assessing power
Focus on rights other than voting rights
Voting rights are relevant 4
Less than a majority of voting rights
Majority of voting rights
Rights held by others
consider: consider:
Agreements with other vote holders
Other contractual agreements
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
15
g
Potential voting rights 4B
De facto power 4C
5/29/2013
9
Only substantive rights considered
Substantive rights
…and their holder has a practicalThe rights are exercisable when
4A
Factors to consider
…and their holder has a practical ability to exercise the rights
The rights are exercisable when decisions about the relevant activities of an investee need to be made…
Are there barriers that prevent holder from exercising the
rights?
Do several parties need to agree for the
rights to become exercisable or
ti l?
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
16
g
Would party holding the rights benefit from their
exercise?
operational?
Potential voting rights
Potential voting rights considered only if substantive
Purpose and design also considered
4B
p g
B C
Option to acquire majority of voting shares in C exercisable in 25 days and deeply in the money
Next shareholder meeting at which
B is likely to control C: its rights are essentially equivalent to those of
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
17
Next shareholder meeting, at which decisions to direct the relevant activities are made, is in eight months
Special meeting to change existing policies over relevant activities can be called at any time with 30 days’ notice
equivalent to those of ordinary shareholders in
C
5/29/2013
10
Knowledge check 3
Which of the following statements is correct with regard to potential voting rights?
A. Consideration of potential voting rights is a new principle introduced in p g g p pIFRS 10 for the first time.
B. Consideration of potential voting rights is not a new principle introduced in IFRS 10 for the first time, but its consideration differs from that under IAS 27.
C.The consideration of potential voting rights in IFRS 10 results in convergence between IFRS and U.S. GAAP.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
18
D.The consideration of potential voting rights only is applicable for the evaluation of investees which are special purpose vehicles.
Knowledge check 3 – Debrief: Correct answer is B
A. Incorrect
B. Correct, consideration of potential voting rights is not a new principle i t d d i IFRS 10 f th fi t ti b t it id ti diff fintroduced in IFRS 10 for the first time, but its consideration differs from IAS 27.
C. Incorrect
D. Incorrect
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
19
5/29/2013
11
Assess whether investor has de facto power over investee
Investor considers all facts and circumstances
Size of investor’s holding of
4C
Ste
p 1
Size of investor’s holding of voting rights relative to size
and dispersion of holdings of other vote holders
Potential voting rights
Other contractual
arrangements
Thi i t
This is sufficient evidence that investor has
power
This is sufficient evidence that
investor does not have power
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
20
Step 2 – Investor considers additional facts and circumstances
Control analysis continued (returns…)
Investor does not have control
This is not conclusive
power have power
Assess whether investor has de facto power over investee (continued)
These factors may be sufficient
evidence of power
Investor holds 48 percent of investee
Remaining voting rights held by thousands of h h ld > 1 t
4C
These factors may be sufficient
evidence that the investor does not
have power
Investor holds 45 percent of investee
Two other investors each hold 26 percent of the voting rights
No other arrangements that affect decision making
evidence of power shareholders, none > 1 percent
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
21
These factors may not be conclusive – Step 2 analysis
required
Investor holds 35 percent of investee
Three other investors each hold 8 percent of voting rights
Remaining 41 percent widely dispersed
No other arrangements that affect decision making?
5/29/2013
12
Assess whether investor has de facto power over investee (continued)
Investor considers additional facts and circumstances
Additional factors
4C
Pattern of participating in voting at
previous shareholder
meetings
Additional factors
Evidence of power
Special relationships
Level of investor’s
exposure to variability in
returns
Ste
p 2
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
22
If this is unclear
Investor does not control investee
Assess whether investor has de facto power over investee (continued)
Step 1 not conclusive
Investor holds 35 percent of investee
Three other investors each hold 8 percent of voting rights
Remaining 41 percent widely dispersed
4C
No other arrangements that affect decision making
Decisions about relevant activities require approval of majority of votes
At recent shareholder meetings, 75 percent of voting rights cast
That is, P holds only 47 percent (35/75) of active voting rights
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
23
5/29/2013
13
Knowledge check 4
Which of the following statements is correct with regard to de facto power?
A. IFRS and U.S. GAAP are converged with respect to de facto power.
B IFRS 10 b i f d id th t i t d i l i IAS 27 ithB. IFRS 10 brings forward guidance that existed previously in IAS 27 with respect to de facto power.
C.An investor must hold at least 40 percent of the voting interest in an entity to conclude that it has de facto power.
D. IFRS 10 is explicit that de facto power can lead to consolidation of an investee even when an investor owns less than a majority of the investee’s voting interest.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
24
g
Knowledge check 4 – Debrief: Correct answer is D
A. Incorrect
B. Incorrect
C. Incorrect
D.Correct, IFRS 10 is explicit that de facto power can lead to consolidation of an investee even when an investor owns less than a majority of the investee’s voting interest.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
25
5/29/2013
14
Rights other than voting rights are relevant
Other factors to considerPurpose and design
Evidence of practical ability to direct e g in estor can appoint
Involvement, d i i
4D
Special relationships, e.g., significant portion of investee’s
activities either involve or conducted on behalf of investor
Large exposure to variability in
returns
direct, e.g., investor can appoint or approve investee’s key
management personnel who direct relevant activities
decisions, contractual
arrangements at investee’s inception
Circumstances in which relevant activities occur
Commitment to
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
26
Greater weight given to evidence of practical ability to direct
ensure that investee continues
to operate as designed
Is investor exposed to or has rights to variable returns?
Distributions and changes in value of investment in investee
Fees, exposure to loss from providing credit or
liquidity support, residual interest in the net assetsReturns vary as a
5
interest in the net assets, tax benefits, etc.
Returns that are not available to other interest holders, such as
investor’s ability to use investee’s assets in
combination with its own to
Returns vary as a result of
performance of investee and can be only positive,
only negative, or positive and
negative
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
27
combination with its own to achieve economies of scale
5/29/2013
15
Knowledge check 5
Which of the following statements is correct with regard to variable returns?
A. Variable returns only include exposure to downside but not upside.
B V i bl t i t hi h i t d U S GAAP d thB. Variable returns is a concept which exists under U.S. GAAP and the IFRS 10 definition is the same of for U.S. GAAP.
C.Variable returns include only exposure to net income and changes of the fair value of equity of the investee.
D.Variable returns is a broad concept and would include for various forms of returns and exposures to upside and downside including share of net income, fees, and synergies available to the investor from its investment.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
28
, , y g
Knowledge check 5 – Debrief: Correct answer is D
A. Incorrect
B. Incorrect
C. Incorrect
D.Correct, variable returns is a broad concept and would include for various forms of returns and exposures to upside and downside including share of net income, fees, and synergies available to the investor from its investment.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
29
5/29/2013
16
Assess whether there is a link between power and returns
=PowerExposure to variability in returns
The investor is a principal
++
Use of the power to generate
returns for
6
itself
=++PowerExposure to variability in returns
The investor is an agent
Use of the delegated power for the benefit
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
30
of others
Is investor a principal or an agent?
Does a single party hold substantive rights to remove the decision maker without cause?
no
6
Is the remuneration “at market,” i.e.,
Is it commensurate with services provided
Does it include only terms, conditions, amounts customarily present in arrangements for similar services and level of skills on arm’s-length basis?
yes
no
yes no
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
31
Investor is a principal
Investor is an agent
Continue the analysis
…
5/29/2013
17
Is investor a principal or an agent? (continued)
Consider the four indicator groups
6
Scope of decision-making authority
Remuneration
Rights held by other parties
Other interests held
(“Economic interests” aggregated)
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
32
Investor is an agentInvestor is a principal
Relationships with other parties
Investor considers whether other parties act on its behalf, i.e., as its de facto agents
Decision-making rights delegated to an agent are treated as held by investor directly
Examples of entities that
may be acting as de
factoagents:
Related parties of investor
Party that has a close business relationship with investor
Party whose governing body/key management personnel is almost the same as investor’s
Party that received its interest in investee as contribution or loan from
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
33
agents: yinvestor
Party that cannot finance its operations without subordinated support from investor
Party that has agreed not to sell, transfer, or encumber its interest in the investee without investor’s prior approval
5/29/2013
18
Effective date: January 1, 2013
Consolidation suite effective for years beginning on or after January 1, 2013
E l d ti itt dEarly adoption permitted provided that entire suite of consolidation standards adopted at the
same time
Entities encouraged to provide IFRS 12 information before effective date
This doesn’t trigger early adoption
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
34
The IASB issued in June 2012 an amendment to provide additional transitional relief limiting the requirement to provide adjusted
comparative information to only the preceding comparative period.Furthermore, it provides relief from certain disclosure requirements
for periods before IFRS 12 is first applied.
Knowledge check 6
Which of the following statements is correct with regard to the effective date and transition requirements of IFRS 10?
A. An entity can opt to apply IAS 27 (2008) indefinitely if it meets the y p pp y ( ) ydefinition of a financial institution.
B. An entity cannot early adopt IFRS for its fiscal year ending December 31, 2012.
C. IFRS 10 has to be applied retrospectively without exception.
D. IFRS 10 is mandatorily effective for fiscal years beginning on or after January 1, 2013.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
35
y ,
5/29/2013
19
Knowledge check 6 – Debrief: Correct answer is D
A. Incorrect
B. Incorrect
C. Incorrect
D.Correct, IFRS 10 is mandatorily effective for fiscal years beginning on or after January 1, 2013.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
36
IFRS compared with U.S. GAAP
Single consolidation model1) Variable Interest Entity
IFRS U.S. GAAP
Single consolidation model2) Voting Interest Entity
De facto control principle No de facto
control principle for votinginterest entities
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
37
Consider potential votingrights if substantive
In general, no consideration of potential voting rights for voting
interest entities
5/29/2013
20
IFRS compared with U.S. GAAP (continued)
Uniform accounting policies No uniform accounting policies
IFRS U.S. GAAP
required by the group entities required by the group entities
“Silo accounting” conceptapplicable for all investees
“Silo accounting” only applicable
to VIEs
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
38
KPMG Institutes and training
About the KPMG IFRS Institute
The KPMG IFRS Institute, part of the KPMG Institute Network, has been created as an open forum where board and audit committee members, executives, management, stakeholders, academia and government representatives can share knowledge gain insight and accessacademia, and government representatives can share knowledge, gain insight, and access thought leadership about the evolving global financial reporting environment. To visit the IFRS Institute, go to www.kpmginstitutes.com/ifrs-institute.
Executive Educationwww.ExecEd.kpmg.comGroup live, instructor-led CPE credit accounting courses, seminars, workshops, and update conferences for corporate accountants and financial executives
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
39
5/29/2013
21
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future No one should act uponcontinue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation.
© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 182377
The KPMG name, logo and “cutting through complexity” are registered trademarks or trademarks of KPMG International.