SEC Non-GAAP Comment Letters and Firm Disclosures

2019 ◽  
Author(s):  
Dain C. Donelson ◽  
Antonis Kartapanis ◽  
Colin Koutney
Keyword(s):  
Comment Letters

The Development of Auditing Standards at the PCAOB and Related Audit Practitioner Input

2020 ◽  
Author(s):  
L. Tyler Williams ◽  
W. Mark Wilder
Keyword(s):  
Standard Setting ◽  
The Public ◽  
Setting Process ◽  
Public Company ◽  
Auditing Standards ◽  
Audit Standard ◽  
Comment Letters ◽  
Feedback Responses

The Public Company Accounting Oversight Board (PCAOB; Board) maintains that constituent feedback plays an essential and dynamic role in its audit standard-setting process. We examine a major source of constituent feedback, responses to standard-setting questions, using a sample drawn from the original proposals of fourteen PCAOB auditing standards. We find that after receiving comment letter feedback to the standard-setting questions, the Board revises approximately half of its guidance tied to those questions before it finalizes auditing standards-a finding consistent with the Board's assertion that it carefully considers constituent perspectives as it develops new regulation. We also explore the related comment letters of eight professional auditing firms subject to the PCAOB's annual inspection program and discover varying levels of opposition to and support for the PCAOB's proposed authoritative guidance. We observe PCAOB revision to authoritative guidance highly contested by the firms in more than three-fourths of cases of standard-setting questions and PCAOB non-revision to guidance highly supported by the firms in more than ninety percent of cases.

External Legal Counsel and the SEC M&A Comment Letters

2021 ◽  
Author(s):  
Pawel Bilinski ◽  
Ivana Raonic ◽  
Junzi Zhang
Keyword(s):  
Legal Counsel ◽  
Comment Letters

The Effects of Regulatory Scrutiny on Tax Avoidance: An Examination of SEC Comment Letters

2016 ◽  
Vol 91 (6) ◽  
pp. 1751-1780 ◽  
Author(s):  
Thomas R. Kubick ◽  
Daniel P. Lynch ◽  
Michael A. Mayberry ◽  
Thomas C. Omer
Keyword(s):  
Indirect Effect ◽  
Avoidance Behavior ◽  
Tax Avoidance ◽  
Regulatory Scrutiny ◽  
Comment Letters ◽  
To Receive ◽  
Tax Costs

ABSTRACT This study examines the tax avoidance behavior of firms prior to the issuance, and following the resolution, of SEC tax comment letters. We find that firms that appear to engage in greater tax avoidance are more likely to receive a tax-related SEC comment letter. We also find that firms receiving a tax-related SEC comment letter, relative to firms receiving a non-tax comment letter, subsequently decrease their tax avoidance behavior consistent with an increase in expected tax costs. Additionally, we document evidence consistent with other firms that do not receive a comment letter reacting to multiple publicly disclosed tax-related comment letters within their industry by increasing their reported GAAP ETR, consistent with an indirect effect of regulatory scrutiny on certain types of tax avoidance.

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