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Presentation and disclosure



                       Variable lease payments

                       ASC 842 does not explicitly address whether variable lease payments made for a finance lease should
                       be presented as lease expense (i.e., an operating expense) or interest expense in the income statement.
                       We believe that either presentation is appropriate but careful consideration should be given to the
                       economics of the lease when making this determination. For example, if a lease with all variable
                       payments is classified as a finance lease, no lease liability would be recorded; in this case, it would be
                       difficult to support presentation of the variable payments as interest expense given there is no liability
                       associated with the lease.

            9.2.2.2    Operating lease

                       A lessee should present the lease expense of an operating lease as a single operating expense in income
                       from continuing operations. As noted in LG 4.4.2, lease expense should be calculated on a straight-line
                       basis. Although a lessee is not required to provide the components of lease expense, financial
                       statement users will be able to derive certain information from the quantitative disclosures, including
                       the weighted average discount rate. See LG 9.2.5 for further discussion.

              9.2.3    Statement of cash flows

                       The following subsections address how a lessee should present cash payments for finance and
                       operating leases in the statement of cash flows.

            9.2.3.1    Finance lease

                       A lessee should classify cash payments with respect to finance leases as follows:

                          □   Cash payments for the principal portion of the lease liability arising from a finance lease
                              should be classified as financing activities

                          □   Cash payments for the interest portion of the lease liability arising from a finance lease should
                              follow the guidance in ASC 230. These amounts would generally be classified as operating
                              activities

                          □   Variable lease payments and short-term lease payments not included in the lease liability
                              should be classified as operating activities

            9.2.3.2    Operating lease

                       A lessee should generally classify cash payments arising from operating leases within operating
                       activities. The exception to this relates to lease payments associated with the cost to bring another
                       asset to the condition and location necessary for its intended use that are capitalized as part of the cost
                       of the asset. For example, certain lease payments incurred while building property, plant, or
                       equipment would be capitalized and should be classified as investing activities rather than operating.

            9.2.3.3    Noncash transactions

                       As discussed in LG 9.2.5, ASC 842 requires certain quantitative disclosures. One such disclosure
                       relates to supplemental noncash information on lease liabilities arising from obtaining right-of- use
                       assets. Furthermore, ASC 230 requires disclosures for all non-cash investing and financing





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