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In our comment letter, we support the FASB’s objective to reduce the cost and complexity of applying the transition guidance in ASC 842, Leases. We believe the proposal could contribute to that objective by helping to clarify which land easements should be evaluated under ASC 842. However, we recommend that the Board clarify that the practical expedient would not apply to land easements previously accounted for as leases. In addition, we suggest that the Board consider additional clarifications on how to evaluate land easement contracts after the effective date of the new leases standard.