Under ASU 2016-09, all windfall and shortfall tax effects of stock compensation will run through earnings in the P&L. When vesting in performance awards is tied to earnings per share, this could make it harder to set the targets in the future because it will be harder to forecast earnings. And, for awards that have already been granted, it might make the current targets easier to achieve (or harder to achieve if the company is experiencing tax shortfalls).
Adjusting EPS Targets
Companies might be tempted to adjust EPS targets for existing performance awards, to reflect the company’s new expectations in light of ASU 2016-09. But, unless the terms of the award already address what happens when there is a change in GAAP prior to the end of the performance period, this could be hard to do. Modifications of targets could cause the awards to no longer be exempt from Section 162(m) and could have other implications.
If the targets aren’t modified, companies will likely have to adjust their forfeiture estimate for the awards.
Non-GAAP EPS
Many companies use a non-GAAP calculation of EPS for purposes of their performance awards. Where the EPS calculation already excludes expense from stock compensation, it should also exclude any tax effects attributable to stock awards. And where this is the case, ASU 2016-09 won’t impact the likelihood of the targets being achieved.
Survey Says
In our May quick survey, we asked what companies plan to about their performance awards in which vesting is tied to EPS. Here’s what they said:
16% use a non-GAAP measure of EPS that already excludes stock compensation expense
2% are planning to adjust their EPS targets
35% are not planning to adjust their EPS targets
48% don’t know what they are going to do about their EPS targets
One of the primary ways in which ASU 2016-09 changed stock plan accounting practices is to require that all tax effects be recognized in the income statement. Excess tax savings increase earnings (by reducing tax expense) and tax shortfalls reduce earnings (by increasing tax expense). For some companies, this results in a lot of volatility in earnings, earnings per share, and effective tax rates. It also makes it harder to forecast earnings.
PwC found that some companies are providing detailed commentary on the impact of ASU 2016-09 on earnings per share. Here is a sample disclosure that PwC found:
“[The Company] anticipates fiscal year 2017 diluted EPS from continuing operations to be in the range of $5.38 to $5.58, which includes an expected benefit of about 25 to 30 cents from the adoption of ASU 2016-09. Excluding the benefit of adopting the updated accounting standard, [The Company] anticipates fiscal year 2017 diluted EPS from continuing operations to be in the range of $5.13 to $5.28.”
Effective Tax Rates
PwC found similar disclosures for effective tax rates. From another company:
“We expect an effective tax rate of 26% – 27.5%, after a projected reduction of 350 – 450 basis points related to the implementation of the new accounting standard for the tax benefit of employee share-base compensation.”
Earnings Guidance
Finally, PwC found some companies that had updated previously disclosed earnings and tax rate forecasts:
“[The Company] now anticipates its effective fiscal year 2017 tax rate to be between 32 percent and 33 percent versus its previous assumption of 30 percent and 31 percent, reflecting a 2-point reduction versus year ago compared to the previously assumed 4-point reduction from adopting ASU 2016-09. The company’s updated assumptions for its fiscal year effective tax rate reflect lower than anticipated exercises of [the Company’s] stock options in the first quarter and the company’s revised outlook for full-year stock option exercises. As noted, the company had previously communicated that the benefit to be realized from the adoption of ASU 2016-09 could vary significantly.”
Last week, I used an example to illustrate the impact the new tax accounting rules under ASU 2016-09 will have on companies’ P&L statements. If your company is profitable, this is something you can do using your own financials. In this week’s blog entry, I explain how.
Finding the Numbers
I found all the numbers for my example in the company’s 10-K. I didn’t even have to pull up the full 10-K; I used the interactive data on EDGAR—it took me about 5 minutes. Here’s where to look:
You can find your company’s net earnings, tax expense, and basic EPS in your income statement (“income statement” is the less cool way to say “P&L,” which is shorthand for “profits & loss statement”).
You can usually find your excess tax benefit or shortfall in your cash flow statement or the statement of stockholders’ equity (or you may already know this amount, if you manage the database that this information is pulled from).
The number of shares used in your basic EPS calculation will be indicated in either your income statement or your EPS footnote.
What To Do With the Numbers
Once you have collected that data, you can do the following:
Post-Tax Earnings: The tax benefit represents how much post-tax earnings would be increased (or, if you have a shortfall, how much earnings would be decreased).
Effective Tax Rate: Subtract the tax benefit (or add the shortfall) to tax expense and divide by pre-tax earnings to determine the impact on your effective tax rate.
Earnings Per Share: Divide the tax benefit (or shortfall) by the shares used in the basic EPS calculation to figure out the impact on basic EPS.
Do these calculations for the past several years to see how much the impact on earnings varies from year to year.
Stuff You Should Be Aware Of
This exercise is intended to give you a general idea of the impact of the new tax accounting rules for your company. There are lots of complicated rules that govern how earnings and tax expense are calculated that have nothing to do with stock compensation, but that, when combined with the rules for stock compensation, could change the outcome for your company. This is especially true if your company isn’t profitable—if you are in this situation, it may be best to leave the estimates to your accounting team.
Also, I’ve suggested calculating the impact only on basic EPS because it’s a little harder to figure out the impact on diluted EPS. In diluted EPS, not only will the numerator change, but the number of shares in the denominator will change as well, because excess tax benefits no longer count as a source of proceeds that can be used to buy back stock. See my blog entry, “Update to ASC 718: Diluted EPS” for more information).
The FASB’s update to ASC 718 is a gift that keeps on giving, at least in terms of blog entries. Today I discuss something many of you may not have considered: the impact the update will have on the calculation of common equivalents under the Treasury Stock Method.
EPS: A Story of a Numerator and a Denominator
Earnings per share simply allocates a company’s earnings to each share of stock. It is calculated by dividing earnings (the numerator) by the number of shares common stock outstanding (the denominator). Public companies report two EPS figures: Basic EPS and Diluted EPS. In Diluted EPS, the denominator is increased for any shares that the company could be contractually obligated to issue at some point in the future, such as shares underlying stock options and awards. These arrangements are referred to as “common equivalents.”
A Quick Refresher on the Treasury Stock Method
The Treasury Stock Method is used to determine how many shares should be included in the denominator of Diluted EPS for all of the arrangements that could obligate the company to issue shares in the future. Under the Treasury Stock Method, companies assume that all of these arrangements are settled (regardless of vesting status), the underlying shares are issued, and any proceeds associated with the settlement are used to repurchase the company’s stock. The net shares that would be issued after taking into account the hypothetical repurchases increase the denominator in the EPS calculation.
The possible sources of settlement proceeds include any amount paid for the stock, any windfall tax savings (“windfall” is the operative word here), and any unamortized expense. For a more detailed explanation, see the chapter “Earnings Per Share” in Accounting for Equity Compensation in the United States.
What the Heck are “Windfall” Tax Savings?
“Windfall” tax savings are those that increase paid-in capital rather than decreasing tax expense. Normally, tax savings result from expenses and reduce the company’s tax expense. But this isn’t always the case with the tax savings from stock compensation. Sometimes the company’s tax deduction is greater than that expense recognized for an award. Currently when that occurs, the tax savings resulting from any deduction in excess of the expense simply increases paid-in capital; this savings doesn’t reduce tax expense.
How Does the Update to ASC 718 Change This?
Any windfall tax savings have to be accounted for somewhere in the EPS calculation. Right now, because these savings don’t impact tax expense or earnings, and thus aren’t reflected in the numerator of the EPS equation, they are treated as a source of settlement proceeds and reduce the denominator.
Once the update goes into effect, this is all changed. All tax savings, windfall or otherwise, will reduce tax expense and increase earnings, which means these savings will be reflected in the numerator for EPS. Because the savings will be reflected in the numerator, they will no longer be treated as a source of settlement proceeds under the Treasury Stock Method.
You Have to Admit, It Does Simply Things
The upshot is that, once a company has adopted the update to ASC 718, the settlement proceeds when applying the Treasury Stock Method to awards will be limited to just two sources: the purchase price and any amortized expense. Windfall tax benefits will be eliminated as a source of proceeds.