Going Concern

Comp Watch ’11: PwC Partners Making Deloitte Counterparts Look Like Peasants

Caleb Newquist
September 13, 2011

The FT reports that the average partner in the UK took home £763,000, up 1% from last year. Ian Powell, the Chairman of the UK firm, took home £3.7 million. The average take home at P. Dubs puts Deloitte partners to shame who only managed to scrape together an average of £758,000, down from £873,000. What does the mean for the partners in the States? Probably nothing but it could indicate that Deloitte’s reign as the biggest of the Big 4 could be a one year wonder. [FT]

Here Are the Tax Breaks That Obama Wants Cut to Pay for the Jobs Bill

Caleb Newquist
September 12, 2011

If you’re in the $200k+ club, a hedge fund manager or corporate jet owner, you won’t be pleased. From Reuters:

— A limit on itemized deductions and certain exemptions on individuals who earn over $200,000 and families who earn over $250,000, which would raise roughly $400 billion over 10 years.

— A proposal to treat carried interest earned by investment fund managers as ordinary income rather than taxing it at capital gains rates, which would raise $18 billion.

— Eliminating certain oil and gas industry tax breaks that would raise $40 billion.

— A change in corporate jet depreciation rules that would raise $3 billion.

Right. Can’t forget the oil companies.

Obama seeks $467 billion in tax changes to fund jobs plan [Reuters]

PwC
Salaries

Comp Watch ’11: Performance Ranking Distribution and More Bonus Details for PwC

Caleb Newquist
September 12, 2011

Earlier this month, PwC announced that they were throwing new labels on their performance review buckets for FY ’12. Those of you that can walk on water will be called “Top Performers,” better-than-average mortals will be “Outstanding Performer,” the meaty part of the curve is “High Performer,” rubes will land in “Needs Improvement” while the you Sling Blade mofos will be “Unsatisfactory.” While your mothers and I both believe that you’re all worthy of “Top Performer” status, P. Dubs doesn’t share our viewpoint. This morning, Assurance Leader Tim Ryan sent an email to all opiners regarding the distribution of the “Relative Perhe email was sent to us by a tipster and it includes this table:

As you can see, more than half of the new associates will be coddled with a “High Performer” ranking their first year in order to keep them on the hook. In year 2, we see a 20% drop distributed over “Top Performer” and “Outstanding Performer.” The table shows that, over time, if you aren’t consistently falling into the TP or OP categories, you won’t be wearing autumnal hues for long. This seems fair, although we all know that understanding how performance evaluations are determined is like trying to understand why Michelle Bachmann attempted to speak Yiddish.

The email also goes on to describe the three bonuses that will be available to assurance professionals: Credential (that’s your CPA), Contribution, and Annual Performance. Here are the details of each:

Credential Bonus
Associates are eligible to receive a Credential Bonus if they pass their primary credential exam, consistent with prior years.

Contribution Award
To provide a consistent approach to timely recognition of exceptional contributions, associates and senior associates are eligible to receive a semi-annual Contribution Award, in December and the spring. This award will recognize contributions that exceed the expectations at each level (e.g., unique client contributions to the team, extraordinary effort, enhanced quality, significant assistance to another practice). Individual awards will be determined through a formalized and consistent semi-annual process. This award is not contingent upon RPR or credential status.

Annual Performance Bonus
• Senior associates through directors/senior managers will be eligible to participate in the Annual Performance Bonus. The allocation of these bonus awards will be based on staff level and relative performance rating.

• The total Annual Performance Bonus pool is based on achieving our quality and financial performance goals. Successful achievement of our goals will result in award ranges as noted in the chart. These ranges will increase if we exceed our goals (as was the case in FY11 when we increased the overall performance pool by 10%) and decrease if we do not achieve our goals.

• An individual’s bonus within the target award range will depend on the total bonus dollars allocated to her/his market or business unit based on quality and financial performance, as well as the individual’s contributions in relation to peers within their performance category.

• It is expected that all staff at the senior associate level and above rated High Performer or above will participate in the Annual Performance Bonus. Please note, staff who have not worked the full year may receive a prorated bonus award based on the bonus ranges.

And the representative tables:

Just a few thoughts:

1. Don’t fuck around when it comes to the CPA Exam.

2. Even though Contribution Awards “will be determined through a formalized and consistent semi-annual process,” I can’t help but interpret this as “a political and opaque determination that we’ll throw together at the last minute.”

3. You’re probably wondering about “quality and financial performance goals” mentioned with the APB. Here’s the scoop on those:

Quality performance goals
• Inspections: Reduce the number and severity of non-compliant audits identified through inspections
• Training: Complete participation in all required training, including passing applicable assessments
• Planning: Improve the timing of planning and phasing of our audit work, including the appropriate use and leverage of our delivery model.

Financial performance goals
• Revenue: Achieve our annual revenue budget, which includes a 4.9% revenue growth target
• Contribution Margin: Achieve our contribution margin budget
• Cash Collections: Achieve our monthly cash collection plan

Achieving our quality and financial performance goals will require both an individual and team effort. Reaching our quality goals will require staff to continue to focus on our compliance with auditing standards, concentration on continuous improvement and enhanced management of all engagements. Meeting our financial performance goals will be dependent upon each staff charging all their time and billing timely for all client services.

Assurance quality and financial performance results will be shared with you on a quarterly basis.

So while the increased transparency is nice, the quality and financial performance will be one of those things where you’ll be told the numbers; you’ll hear the story behind the numbers; the end. You could audit your ass off, ace every diversity, independence, and ethics training but if business is down or flat (looking probable) you’ll simply have to accept it.

Anyway P. Dubbersteins, try to digest this and discuss your ecstasy over the latest details.

News

AICPA Practically Begging the Financial Accounting Foundation to Develop Private Company GAAP

Caleb Newquist
September 12, 2011

Were you aware that over 2,500 letters have been sent to the Financial Accounting Foundation “demanding” the development of private company GAAP as well as a separate independent board to oversee the standards? If no, why not? If yes, why aren’t you feigning rage, issuing press releases with impatient statements by various bigwigs? If you’re the AICPA, that’s exactly what you’re doing:

For almost 40 years, the pleas of private companies to set standards for financial reporting that are more relevant too often have been ignored. The American Institute of Certified Public Accountants (AICPA) believes that it is time for the Financial Accounting Foundation (FAF) to listen to the constituents who have written to FAF demanding differential financial reporting standards for private companies and a separate independent board to oversee those standards. There are approximately 28 million privately held U.S. companies, accounting for more than 50 percent of our economy.

“Ninety nine percent of the letters from the privately held company constituency demanded that the Financial Accounting Foundation create differential standards for privately held companies,” said Barry Melancon, AICPA president and CEO. “We’ve studied this problem for far too long.”

Pick up the pace, FAF. People are getting antsy.

[via AICPA]

KPMG

KPMG Remembers 9/11

Caleb Newquist
September 12, 2011

Yesterday was the tenth anniversary of 9/11 and memorials were held all over the country. Thousands of KPMG employees volunteered at over 200 non-profits to mark that tragic day including over 100 at PS 161 in New York and 70 at the wreath-laying ceremony at the Pentagon in Washington, D.C. Nothing more really needs to be said other than kudos to KPMG for their “Service of Remembrance.” Drop your own remembrances in the comments and if your firm marked the 10th anniversary in some way (aside from t-minus 4 days until the corporate tax filing deadline), let us know below or email us. [KPMG]

This Trick May Give CPA Candidates a Sneak Peek at Whether They Passed the Final Section of Their Exam

Adrienne Gonzalez
September 12, 2011

Maybe we shouldn’t publish this, lest TPTB catch on and close this loophole but as it’s soon to be CPA exam score release season, we figured it might be helpful to share this little trick to get your score early.

Note, word is it only works if you are on your last section and testing in a NASBA state. It doesn’t work all the time and will really only give you your score a day or so earlier than you would have actually received it from your state.

So if you’re waiting for a score now, don’t bother, it doesn’t work until the AICPA releases scores to NASBA, which is supposed to be within a 7-10 day period beginning the third week of September for this quarter.

To try it, follow these simple steps:

1. Go to the CPA exam section of NASBA’s website and select Ohio regardless of which state you are testing in.

2. Choose Apply Now under the “Re-applying for the Uniform CPA Examination” tab.

3. You will be asked if you have an Ohio jurisdiction ID. Choose no and it will ask you if you have a Social Security number. Choose yes.

4. Follow the rest of the prompts, plug in the information it asks you for and if you get the following message, congratulations, the loophole worked and you passed:

We are sorry. Our system shows that you have already passed all parts of the Uniform CPA Examination. If you have questions, please call your Coordinator at the number given below. Please call the number below.

800-CPA-EXAM
615-880-4250

Some have stated that the loophole also works if you’ve failed. If you get in and see the exam section you are checking on not grayed out, that means it’s allowing you to get a new NTS which obviously means you did not pass.

Bottom line: maybe it works, maybe it doesn’t. If you’re driving yourself insane refreshing your score page waiting for an answer, maybe it wouldn’t hurt to try at the end of the month but you’re really only getting the news a few hours earlier than you would have if you just waited.

Accounting News Roundup: SarbOx’s Clawbacks Disappoint;Tax Credits Boost Video Game Industry; Ex-E&Y Partner’s Conviction Sticks | 09.12.11

Caleb Newquist
September 12, 2011

Clawbacks Without Claws [NYT]
Under the Sarbanes-Oxley Act of 2002, the Securities and Exchange Commission was encouraged to hit executives where it hurts — in the wallet — if they certified financial results that turned out to be, in a word, bogus. SarbOx was supposed to keep managers honest. They would have to hand back incentive pay like bonuses, even if they didn’t fudge the accounts themselves. That, anyway, was the idea.

At 9/11 ceremonies, tearful storytelling and still-vivid memories [WaPo]
The anniversary of the attacks — the first since the killing in May of Osama bin Laden — unfolded through tearful storytelling and still-vivid memories. Political and religious leaders urged the nation to recall the spirit of common purpose that defined that day and its immediate aftermath but which has faded amid the acrimonious debate over America’s response to the attacks and the effect that response has had on the nation’s politics, finances and values.

How to Make Business Want to Invest Again [NYT]
According to a 2008 study by the Organization for Economic Cooperation and Development, “Corporate taxes are found to be most harmful for growth.” Tax reform that reduced the burden on capital income and shifted it toward consumption would improve prospects for long-run growth and, in so doing, encourage greater investment today. Yet it would be overly optimistic to think that any single public policy, by itself, could lead to the kind of robust investment spending seen in previous recoveries. Myriad government actions influence the expected future profitability of capital. These include not only policies concerning taxation but also those concerning trade and regulation.

Capital gains tax rates benefiting wealthy feed growing gap between rich and poor [WaPo]
For the very richest Americans, low tax rates on capital gains are better than any Christmas gift. As a result of a pair of rate cuts, first under President Bill Clinton and then under Bush, most of the richest Americans pay lower overall tax rates than middle-class Americans do. And this is one reason the gap between the wealthy and the rest of the country is widening dramatically.

Rich Tax Breaks Bolster Makers of Video Games [NYT]
The United States government offers tax incentives to companies pursuing medical breakthroughs, urban redevelopment and alternatives to fossil fuels. It also provides tax breaks for a company whose hit video game this year was the gory Dead Space 2, which challenges players to advance through an apocalyptic battlefield by killing space zombies. Those tax incentives — a collection of deductions, write-offs and credits mostly devised for other industries in other eras — now make video game production one of the most highly subsidized businesses in the United States, says Calvin H. Johnson, who has worked at the Treasury Department and is now a tax professor at the University of Texas at Austin.

Westchester accountant pleads to tax charge in NYC [AP]
A Westchester County accountant has pleaded guilty to securities fraud, admitting cheating a dozen investors of more than $2 million. Laurence Brown entered the plea in federal court in Manhattan on Thursday. The 64-year-old Katonah, N.Y., resident faces up to 70 years in prison at a Nov. 17 sentencing. Prosecutors said Brown and a business partner carried out the fraud from 2008 to June 2010 by promising that investors’ money would be spent to upgrade a natural gas pipeline in Tennessee.

Ex-E&Y partner’s insider trading conviction upheld [Reuters]
A U.S. court upheld an insider trading conviction of a former partner at accounting firm Ernst & Young LLP, even though the trial judge failed to instruct jurors on a valid defense he had to securities fraud charges. The 2nd U.S. Circuit Court of Appeals in New York on Friday said the defendant James Gansman did not deserve a new trial because he was not prejudiced by the slightly different jury charge given by his trial judge. It also turned aside several other issues raised in the appeal.

‘We Need More Dogs. We Don’t Need No Cats’ [TaxProf]
I have no idea why the TaxProf posted this but I’m glad he did.

Audit
PCAOB

Audit Partners Are About to Get Famous

Caleb Newquist
September 10, 2011

But probably not in ways they would prefer:

In a recently updated standard-setting agenda, PCAOB Chief Auditor Marty Baumann says the board is working on the proposal to address concerns about audit transparency. The board published a concept release in July 2009 that asked for feedback on whether the engagement partner should be required to sign the audit report. Based on feedback to that release and subsequent discussions with the board’s advisory groups, the PCAOB is preparing a new requirement for audit firms to say in their audit reports which engagement partner at the firm supervised the audit and who from outside the audit firm participated in the audit.

PCAOB Plans Rulemaking on Identifying Auditors [CW]

Deloitte
SEC

Deloitte All of a Sudden Caught in an Awkward Three-way with SEC, Chinese Regulators

Caleb Newquist
September 10, 2011

“This is one of the biggest battlegrounds in the transnational regulation of accounting firms,” said Paul Gillis, a visiting professor of accounting at Peking University’s Guanghua School of Management. “Deloitte is between a rock and a hard place. This is a major escalation.” [WSJ, Earlier]

The Serious Questions

Clearly Avoiding the “Sexy” Route, Young CPA Needs Help with Ideas for “Accounting Police” Halloween Costume

Caleb Newquist
September 9, 2011

Now that it’s September, people start getting anxious about their Halloween costumes. Regardless of the two months of football, a World Series, and God knows how many GOP Presidential candidate debates, many will agonize over just what outfit they will wear for approximately 2-3 hours, knowing full well that vomit could end up on it. These days Halloween costumes, for better or worse, focus on the “sexy.” The sexy Little Bo Peep. The sexy priest. This year, I’m really hoping to see the sexy Angry Birds. Anyway, a reader is stumped on how best to approach a recent light bulb moment she had for this year’s outfit:

Hi Caleb,

I am hoping some creative CPAs who read your blog can help me out. A month ago, during one of my trainings, a partner came in and spoke to us about how we should not be seen by our clients as the “accounting police.” Immediately, a lightbulb went off in my head and I thought “HALLOWEEN COSTUME!”, but I have no idea how to pull this off so people will understand it! Any ideas out there?

So we have “accounting” and “police.” Not exactly a lot to work with here but we’ll throw a few ideas out there to get things rolling:

1. Ask four of your friends to join you and go as the letters P-C-A-O-B. Of course, you won’t actually do anything.

2. Simply dress up as police officer and walk around the whole night counting things, not unlike The Count (in fact, I suggest you do the laugh). “What the hell are you supposed to be?” some dope will say. You’ll respond, “A counting police.”

3. Get another idea.

Your suggestions are now welcome.

Leaving Your Accounting Firm? Here’s Your To-Do List Before Your Last Day

Daniel Braddock
September 9, 2011

Ed. note: Got a question from the career advice brain trust? Email us at advice@goingconcern.com.

Happy Friday, folks. Even though Summer Fridays are a thing of the past, we have much to be thankful for. College football on the tube. Ya’ll are getting laid, apparently. And we have some great questions coming into GC.com, like this one here:

I’m ready to leave the Big 4 for industry but want to make sure I don’t m��make the jump. Is there a GC cheat sheet on things to take care of (and take with you) during the 2 week lame duck period after I give my notice? (e.g. contact info, CPE profile, etc.)

I’d love to hear GC readers’ thoughts.

Thanks.

Caleb and I scratched our brains on this one and realized that no – we’ve never really covered this topic. I know some if not all offices allow employees to take care of loose ends during the two week downtime but wouldn’t you rather be prepared to turn everything over on the same day? What I want to do here is cover the basics from the angle that you want to be able to put in your notice and walk out the door the same way. You fill in the details in the comments section below, as I’m sure I’ve missed some of the finer points. Share your horror stories and little victories alike.

1. A. Back up your personal computer files – Technically your work computer is reserved solely for work files and functions but for many of you it is a secondary (even primary) personal computer. I’ve seen laptops turned in with the likes of iTunes libraries, photo albums, tax returns and personal financial tracking files just hanging around in plain sight. You don’t know when HR or your partner will demand to seize your computer (I’ve even seen partners’ commuters seized with no access granted to the files for weeks), so make sure you back everything up onto your own USB drive.

1. B. Delete your personal computer files – Once everything is backed up (make sure the files open on another computer), delete everything personal that’s on the computer. Don’t forget to empty the trash can, too.

2. Get a new wireless plan – If you’re wielding a firm-purchased phone, you’ll be needing to turn that over as well. Take the initiative to get a new phone and have the contacts from your current (firm) phone transferred to your new (personal) device. Every carrier is different, but some will let you buy the new phone without having to activate it immediately, thus giving you the option to walk in there later (presumably, after you’ve dropped the bomb on leadership) and transfer the number over. If you prefer a clean slate and want a new number, so be it.

Also, remember to delete your recent call log, Blackberry Messenger conversations, texting history, sensitive contacts (*cough* your recruiter *cough*), etc. Granted if they really want go through an archive they will, but that really only happens if suspicious/illegal activity is suspected.

3. Organize your client work – This can be a very mundane and verbose task however necessary it may be. The goal here is to make things as easy as possible for your colleagues. Use separate USB drives for different managers and partners. Give everyone an update “open items” list for your active engagements. Make it so organized that a new person to the team would able to seamlessly come on board, read your notes, and pick up where you left off.

Chances are good that you like your co-workers, as one of the most common hesitations staff members have when leaving public accounting is, “I would feel bad leaving my co-workers swamped with my work.” Here’s the deal: they survive. I mean, think about it – how many times has a coworker left before you? Sure, the first few days can be a slow go, but they’re out-of-sight-and-mind within a week. Work is divvied up and completed.

4. Link in with people – I covered this back in June.

5. Mentally prepare yourself – Accounting firms are hit the hardest with employee turnover around this time of year so you need to expect your employer to put up a bit of a fight. Better clients, better work life balance, rotation to another group, verbal praise and affection. (Where was that love when you were working 7:30a to 11:30p during busy season?) You need to prepare for the pressure to be there to turn down your other offer on the spot. There’s nothing wrong with hearing out what your firm can put on the table, but you are under no obligation to turn around and be back on Team PwC or Kamp KPMG during the same meeting you put in your resignation.

Also, remember: you can always go back. Not sometimes. Not usually. ALWAYS. The only thing more valuable to a public accounting firm than its employees are employees that return with private experience.

6. Copy down contact information – There are people you will want to stay in contact with as your careers progress. This should be a no-brainer.

7. One last thing – There’s that colleague with whom you have some tension. Maybe they’re seeing someone, maybe they’re not. Screw the coulda-shoulda-woulda’s and say something before you leave. Be bold.

Deloitte
SEC

SEC Not Amused By Deloitte’s Failure to Produce Documents Related to Company That Held Their Audit Workpapers Hostage

Caleb Newquist
September 9, 2011

Remember Longtop Financial Technologies? Deloitte resigned as auditors of the Chinese company back in May after LFT took some actions that were, shall we say, unusual for an audit client. Among them, “interference by certain members of Longtop management in DTT’s audit process; and […] the unlawful detention of DTT’s audit files.” And there may be some financial statement fraud going on, to boot. What’s even slightly weirder is Deloitte’s resignt to Longtop’s Audit Committee that laid out the specifics:

[A]s a result of intervention by the Company’s officials including the Chief Operating Officer, the confirmation process was stopped amid serious and troubling new developments including: calls to banks by the Company asserting that Deloitte was not their auditor; seizure by the Company’s staff of second round bank confirmation documentation on bank premises; threats to stop our staff leaving the Company premises unless they allowed the Company to retain our audit files then on the premises; and then seizure by the Company of certain of our working papers.

Right. The auditors-almost-taken-hostage situation. Quite a doozy, this one. Based on the history between Deloitte and Longtop, one would think that Green Dot would jump at any chance to exact a little revenge on these shady bastards. NOPE!

From the crack squad at the SEC:

The Securities and Exchange Commission today filed a subpoena enforcement action against Deloitte Touche Tohmatsu CPA Ltd. for failing to produce documents related to the SEC’s investigation into possible fraud by the Shanghai-based public accounting firm’s longtime client Longtop Financial Technologies Limited.

According to the SEC’s application and supporting papers filed in U.S. District Court for the District of Columbia, the SEC issued a subpoena on May 27, 2011, and D&T Shanghai was required to produce documents by July 8, 2011. Although D&T Shanghai is in possession of vast amounts of documents responsive to the subpoena, it has not produced any documents to the SEC to date. As a result, the Commission is unable to gain access to information that is critical to an investigation that has been authorized for the protection of public investors.

“Compliance with an SEC subpoena is not an option, it is a legal obligation,” said Robert Khuzami, Director of the SEC’s Division of Enforcement. “The ability of the SEC to conduct swift and thorough investigations requires that subpoena recipients promptly comply with that legal obligation. Subpoena recipients who refuse to comply should expect serious legal consequences.”

Maybe the email/hand-written letter sent by carrier pigeon (whatever method of communication the Commission is using these days) got lost OR maybe no one at Deloitte Shanghai was in the translating mood that day but it seems slightly strange that Deloitte would just blow this off especially since Longtop screwed them 70 ways to Sunday. Of course these documents could show that Deloitte was really a bunch of pansies and we’re letting LFT run the show until the gross negligence got to the point that they simply couldn’t ignore it anymore. It’s anybody’s guess, really.

UPDATE: The Journal reports that Deloitte claims to be “caught in the middle of conflicting demands by two government regulators,” which could be seen as extremely convenient.

SEC Files Subpoena Enforcement Action Against Deloitte & Touche in Shanghai [SEC]
Court Filing [SEC]
Also see: S.E.C. Asks Court to Force a Release of Papers From China [NYT]

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