On May 18, 2015, TEI submitted comments to the Financial Accounting Standards Board concerning proposed updates to the FASB’s guidance on intra-entity asset transfers. While TEI commended the FASB for its ongoing simplification initiative, which was the asserted basis for the proposed updates, the Institute disagreed with the FASB’s proposed updates for a number of reasons, including TEI’s view that the proposal would increase the risk of earnings management or manipulation and further complicate the analysis of deferred tax items, resulting in increased costs to financial statement preparers with no corresponding benefits to users of financial statements.
TEI's comments were prepared under the aegis of TEI's Financial Reporting Committee, whose chair is Eric Johnson. TEI’s Chief Tax Counsel, Patrick Evans, coordinated the preparation of the comments.