Taxation of Business Entities Ouline

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Taxation of Business Entities Ouline document sample

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							          Developing an Audit Strategy and Updating SASs and SSARS

                                           Ron Clark
                                        Auburn, Alabama
                                  rclark@business.auburn.edu

                                Southeastern Accounting Show
                                         Atlanta, Ga.
                                      August 27, 2009


Auditing:
  • Developing an Audit Strategy
  • Reporting on Control Deficiencies
  • The Clarity Project

Compilations and Reviews
  • Independence
  • Rewrite of SSARS

Audit Strategy
  • We often talk about two approaches to an audit:
          o “Pure substantive” approach where controls are not tested
          o “Controls” approach where internal controls are tested and substantive testing
             reduced

A Stumbling Block
   • Before trying to apply Risk Assessment Standards, we need to recognize the
      unintentional consequences from SAS 55, Consideration of Internal Control in a
      Financial Audit, issued 1987.
   • SAS 55 stated “After obtaining an understanding of the internal control structure, the
      auditor may assess control risk at the maximum level because:
          o Controls are unlikely to be effective, or
          o Evaluating their effectiveness would be inefficient
   • For those assertions where control risk is assessed at the maximum level, document
      conclusion that control risk is at the maximum level but auditor not required to document
      the basis for that conclusion.
   • These two statements supported a “default audit strategy.”

Default Strategy
   • Based on prior knowledge of the client, clients in the same industry or similar size,
      decide to take a pure substantive approach before actually starting the audit
   • To comply with SAS 55, document an understanding of controls based on prior
      knowledge of the client


                                               1
   •   Assess control risk at the maximum
   •   Perform substantive auditing procedures (test of details and balances)

The New Standards
   • The auditor should assess and document the risk of material misstatement and have an
      appropriate basis for that assessment.
   • This basis is obtained by gaining an understanding of the entity and its environment,
      including its internal controls.
   • The default strategy is eliminated
   • The elements of risk assessment, including controls, should be evaluated in relationship
      to each other

The Substantive Approach
   • While the new SASs still recognize the substantive approach as an acceptable audit
      strategy, the implication here is that the auditor must devote more resources to evaluating
      the existence and design of internal controls and identifying inherent risk.
          o Document relationship between client risk and design and implementation of
              controls
          o Selection of substantive procedures based on risk assessment and existence and
              strength of internal controls

Under new standards:
  • Performing substantive procedures is an “Active” decision, not a “Passive” decision
  • Mix of substantive tests may change
  • More documentation

Comparing Risk & Balance Sheet Approaches To Audit
  • New SASs have effectively merged the two approaches into one
  • Risk Assessment must be performed regardless of approach to audit
  • From the Audit Guide on Risk Assessment, “If auditor does not apply guidance, auditor
     should be prepared to explain why”




Flowchart based on the Audit Guide

                                  Developing An Audit Plan

                                                2
                       Input                            Process                                Output

  External Factors
                                                    Risk assessment                         Documented
  Nature of entity                                procedures: Inquiry,                     Understanding
                                                 Observation, Analytics,                     of Client
                                                       Inspection
  Business Risks

                                                  Routine vs. Non-routine
  Financial Analysis
                                                  Transactions/ Processes

  Internal Controls                                                                        Assess Levels of
                                                  Significant Risk Factors                  Inherent and
                                                                                            Control Risk
  Prior Knowledge of
         Client                                      Fraud Risk Factors




                                                            Documented Risk of
                                                           Material Misstatements
                                                                  (RMM)




                               Financial Statement                                          Account/Transaction/
                                   Level Risks                                              Disclosure Level Risks


                                  Adjust audit                                               Relate risk to relevant
 Refine assessed                   planning
  levels of RMM                                                                                    assertions
     and audit
procedures applied
                                                                                         Select an appropriate mix of
                                                                                             auditing procedures
                                    Sufficient
                                   evidence to
              No                      form
                                  conclusions?                             Substantive         Analytical              Test Controls
                                                                           Procedures          Procedures              Effectiveness

                                             Yes
                                                                                           Documented Audit Plan
                           Document conclusions
                             and audit opinion




                                                            3
Where To Begin???
  • To properly apply the Risk Assessment standards, we need to “go through” the flowchart
     multiple times, each time with a different objective.

Our Overall Objective
  • We need an audit plan that is appropriate for the level of the Risk of Material
     Misstatement (RMM)
  • The elements of RMM are Inherent Risk and Control Risks
  • Our assessment of these risks are based on our Understanding of the client

Risk Assessment Procedures:
   • Inquiries
   • Observation
   • Analytics
   • Inspection
   • Auditor not required to perform all the risk assessment procedures for each aspect
      gaining an understanding of the client
   • However, all the risk assessment procedures should be performed by the auditor in the
      course of obtaining the required understanding

First Pass Through Flowchart: Inherent Risk-The Key to Applying the Risk Standards
   • Technical Info Service 8200.09
   • Inherent risk is susceptibility of an assertion to a misstatement assuming there are no
       related controls
   • This implies we need to assess inherent risks before assessing internal controls
   • If we don’t, our assessment of inherent risks may be influenced by our knowledge of
       existing or lack of internal controls

Assessing Inherent Risk
   • Inherent risk must be assessed on two levels:
          o At the entity level, and
          o At the individual account/assertion level

Company Level Risks
  • What does the entity do?
  • How does it distribute its products or deliver its services? Multiple locations?
  • Who are its customers? Characteristics?
  • Who are the major competitors?
  • Who are the major suppliers
  • How does the entity finance its operations?


Industry and Related Regulatory and Other Matters

                                               4
   •   Unique characteristics
   •   Industry conditions (competition, seasonality, demand, etc.)
   •   Regulatory matters (industry specific accounting principles, taxation, environmental
       matters, etc.)

Business Objectives, Strategies, and Risks
   • What are the entity’s key business risks?
   • How may such risks manifest in the entity’s financial statements?

Assess Inherent Risk at Individual Account Level
   • Perform ratio analysis to identify potential “problem” accounts
   • Combining our analysis with understanding of entity risks should provide a basis for
       assessing inherent risks

Second Pass Through Flowchart: Identifying and Assessing Internal Controls
   • Now that we have an overall understanding of the client, we need to gain an
      understanding of the internal controls that are:
         o Implemented
         o Not implemented
   • Again, apply risk assessment procedures to inputs

Assessing Control Risk
   • AICPA has issued several SASs and guides on internal controls
   • While you can still assess control risk at the maximum (ie. place no reliance on controls),
       you must document your basis for doing so
   • For significant accounts, processes, and risk, determine if controls are present
          o Is the Design of controls appropriate?
          o Has control been Implemented (walk-through)?
   • Make decision whether to test Effectiveness of individual controls

Prior Period Audits
   • Can use information about the entity and its environment obtained in prior periods if
       auditor determines info has not changed
   • Make inquiries and perform walk-through to determine whether changes have occurred
       that may affect the relevance of such information.
   • If auditor plans to rely on controls that have not changed since they were last tested, the
       auditor should test the operating effectiveness of such controls at least once every three
       years

Understanding Controls
  • Typical procedures:
         o Observation
         o Inspect documents
         o Walkthrough



                                                 5
           o Information from prior audits if controls not changed and not a significant risk.
             Use Inquires to determine if changes made

Some key questions and answers from AICPA. These relate primarily to smaller entities.

Technical Info Service - 8200.05
   • If auditor anticipates entity does not have effective controls, is auditor required to obtain
      understanding of controls even if designing a substantive audit?
   • Yes

TIS - .06
   • What does “expectation of operating effectiveness of controls” mean?
   • Based on auditor’s understanding of the design and implementation of controls, auditor
        expects the controls to be effective.
   • Will require testing for effectiveness

TIS .07
   • Can an all substantive audit approach be followed even if auditor’s understanding of
       controls are designed effectively?
   • Yes, cost/benefit

TIS - .08
   • Is auditor required to understand the less formal controls within a smaller entity?
   • Yes, part of overall control environment
   • Auditor may decide to test and rely on these less formal controls – Overview by owner is
        example

TIS .10
   • Auditor cannot default to assessing control risk at the maximum
   • Must have basis for assessing control risk, regardless of at maximum or below maximum

TIS .11
   • Even if auditor believes before performing risk assessment procedures that controls are
       nonexistent or ineffective, the auditor must still:
   • Evaluate design of any identified controls
   • Determine if they have been implemented

TIS .12
   • Walkthroughs is an effective method to confirm understanding of controls
   • While standards allows for auditor to use judgment on how often to perform this
       procedure, the reality is they should be performed annually


TIS .13



                                                 6
   •   A client may have many controls but has not documented those controls in accounting
       manuals
   •   Client not required to prepare documentation
   •   However, auditor may need to document control in working papers

TIS .15
   • Just because an auditor decides to not test a control, that does not mean there is a control
       deficiency under SAS 112 (115)
   • Control deficiencies results from:
           o Nonexistent controls
           o Poor design
           o Not implemented
           o Not effective (from test of controls)

TIS .16
   • Bottom line: test (sample) all journal entries:
   • Risk standards require testing of entries made in preparing financial statements
   • SAS 99 requires testing entries made throughout the year

Documented Understanding
   • We now have an in-depth understanding of company, accounting system, and major
     accounts/transactions
   • Next step is to use this information to assess risks

SAS 107 Audit Risk Model

Audit Risk Model
  • AR = IR x CR x DR
  • where:
      AR = Audit Risk
      IR = Inherent Risk
      CR = Control Risk
      DR = Detection Risk (Details/Analytics)
  • Solve for DR:
      DR = AR / (IR x CR)

Applying Model
  • Use qualitative measures
  • LOW = HIGH, MED, LOW
  • LOW = LOW, MED, MED



Restated Model
   • AR = RMM * DR

                                                7
           o AR = Audit Risk
           o RMM = Risk of material misstatement
           o DR = Detection Risk

Factors Influencing our assessment of risks
   • Routine Transactions
   • Some transactions that are routine, noncomplex and systematically processed may have
      lower inherent risks. SAS 99, on Fraud, however, reminds us that some routine
      transactions, such as cash, are more susceptible to fraud, and therefore have greater
      inherent risk.
   • Significant Risk Factors
   • SAS 109 also describes some transactions as significant and requires additional audit
      procedures. Significant risks often relate to non-routine or unusual transactions.
      Transactions requiring manual or management intervention, complex calculations, or
      estimates typically increase the assessment of inherent risk.

Financial Statement Risks
   • Overall responses to address the assessed risks of material misstatement at the financial
      statement level may include
          o Emphasizing professional skepticism
          o Assigning more experienced staff or those with specialized skills
          o Providing more supervision
          o Incorporating additional elements of unpredictability in the selection of audit
              procedures
          o Changes to the nature, timing, or extent of audit procedures

Prior Year Substantive Tests
     • Evidence from substantive procedures in a prior audit provides little or no audit evidence
         for the current period.
     • If evidence obtained from substantive procedures in a prior audit, perform procedures
         during the current period to establish the continuing relevance of the audit evidence.

Summary
  • Gain understanding of client and assess risk on all engagements
  • Audit approach will vary by client, by account, by assertion
  • Mix of substantive and control testing
  • Document link between risk assessment and auditing procedures

Reporting on Internal Control Matters
   • SAS 112, Communications on Controls has been superseded. CPA has three options
      with standards for internal control communications & reporting
   • SAS 115 Communications on controls identified in audit
   • SSAE 15 provides auditor of a non-public entity with the same guidelines as PCAOB AS
      5
   • Follow SSAE when you are performing an integrated examination of internal controls
      while auditing the financial statements
                                                8
   •   Effective 12/15/2008

AICPA Clarity Project
   • Mirrors the IAASB’s Clarity Project
   • Address concerns over the clarity, use of terms, and the length and complexity of auditing
     standards
   • Improve understandability and consistent application of auditing standards
   • Make structural improvements to format of standards

Primary Impact of Clarity Project
   • To establish objectives of each of the standards that provide a conceptual framework for
      the
          o Application of professional judgment and
          o Obligation related to the objective
   • Make structural and drafting changes to make SASs easier to read and understand and to
      simplify the SASs by restructuring them.
   • AICPA will prepare a Mapping Document for each section of Auditing Standards

Redrafting Standards
   • ASB will redraft all SASs
   • There will be little impact from a procedural point of view in the redrafting of the
      standards

Redrafting will:
   • Converge U.S. and ISA standards
   • Some material will be moved to new SASs
   • No significant changes from existing SASs
   • Will move SASs to a more principles based format with application section (audit steps
      to achieve principles)

XBRL
  • XBRL (extensible business reporting language)
  • XBRL is an XML-based framework that provides a standards-based method to prepare,
     publish, extract, and exchange financial statements
  • Not new accounting standards but how we communication in digital language
  • Uses “tags” to identify information

Filing Requirements
    • SEC will phase in required XBRL reporting over three year period beginning June 15,
       2009
    • Other Federal Agencies
          o Bill introduced in Congress in May that would require all Federal Agencies to
              adopt XBRL reporting

What’s New in SSARS

                                                9
Survey on Independence in Compilations
   • ARSC conducted survey to determine how important is independence in a compilation
      engagement

Question 1: Should SSARS No. 1 state that independence is not required in compilation and
delete requirement to disclose lack of independence?
    • Yes 41.8%
    • No 50.1%
    • ARSC Conclusion
           o It would be inappropriate to delete independence requirement or to delete
               disclosing when not independent
    • In compilation, if not independent disclose fact

Question 2: Expand Disclosure - Should SSARS No. 1 be revised to allow accountant to
describe reasons for lack of independence in compilation
   • Yes 57.9%
   • No 32.5%

Exposure Draft
   • Written engagement letter would be required for compilations
   • For both Compilations and Reviews, Independence remains an element for reporting
   • If independent, no change in reporting

Compilations
  • If not independent because:
         o Family relationship
         o Direct financial relationship
         o Perform internal control service
  • Reporting options:
         o State not independent without reason
         o State not independent with general reason

Reviews
   • If not independent because:
          o Perform internal control service
   • Include explanatory paragraph in review report
   • Note: to perform review must be independent in all other aspects other than performing
      internal control services

Rewriting SSARS: An Exposure Draft on dividing SSARS into “Chapters”

Chapter on Reviews
  • Review Risk



                                             10
   •   The terms review evidence and review risks are introduced into the review literature.
       These concepts are the same as in the audit literature.
   •   Will not require same effort on risk assessment as in audit but does add a new dimension
       to Reviews

Chapter on Compilations
  • Knowledge of the Client
         o The client’s business including a general understanding of the client’s
            organization, its operating characteristics, and the nature of its assets, liabilities,
            revenues, and expenses
         o Accounting principles and practices used by the client and unusual accounting
            policies and procedures that come to the accountant’s attention
         o Understanding of the entity’s business is ordinarily obtained through experience
            with the entity or its industry and inquiry of the entity's personnel
  • Term risk assessment not used in new SSARS
  • However, description of understanding client and industry is familiar (sounds like SAS
      wording)




                                                 11

						
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