ACCOUNTING FOR LEASES UNDER ASC 842 16
SALES TAXES AND SIMILAR TAXES
When an entity enters into a lease, taxes may be assessed on the contract by a governmental authority. Those taxes
may be both imposed on and concurrent with a specific lease revenue-producing transaction and collected by the
lessor from a lessee. This includes for example sales, use, value added, and some excise taxes. Unlike lessors (see
Separating Components – Lessor section), lessees do not have a practical expedient to not assess such taxes.
Accordingly, a lessee is required to analyze sales taxes and other similar taxes on a jurisdiction-by-jurisdiction basis to
determine whether those taxes are the primary obligation of the lessor as owner of the underlying asset being leased
(i.e., the tax is a lessor cost) or whether those taxes are collected by the lessor on behalf of third parties (i.e., the tax
is a lessee cost).
If a lessor cost, the tax is accounted for either as part of the consideration in the contract (if the payments
are fixed) or as variable payments that do not depend on an index or a rate.
If a lessee cost, the tax typically does not impact lease accounting for the contract.
Like property taxes and insurance discussed above, the fact that the lessee pays a third-party directly rather than
reimbursing the lessor for the tax does not impact this conclusion.
PRACTICAL EXPEDIENT NOT TO SEPARATE
A lessee may elect as an accounting policy election by asset class, to not separate nonlease components from lease
components and instead, to account for each separate lease component and nonlease components associated with that
lease component as a single lease component.
The FASB provided this practical expedient to reduce cost and complexity in applying ASC 842. However, the election
of the practical expedient results in a larger right-of-use asset and lease liability on balance sheet, and it may also
change classification from an operating to a finance lease (See article 4 on Lease Classification and Key Terms
).
Accordingly, companies will need to consider the pros (e.g., simplicity) and cons (e.g., impact on accounting for the
lease, including balance sheet) of electing the practical expedient for their asset classes.
Nonlease Components “associated with” the Lease Component
ASC 842 does not define or provide guidance for determining whether a nonlease component is “associated with”
the lease component. A literal read of the requirements for the practical expedient may suggest that all nonlease
components, whether provided at a point in time or over time, that are associated with the lease component should
be combined with that lease component when the lessee elects the practical expedient. However, we note that ASC
842 illustrates in Example 11 of ASC 842-10-55 the application of the practical expedient to a contract in which the
nonlease component is maintenance services on construction vehicles. Paragraph BC 149 of ASU 2016-02 also notes
that “[t]he Board also decided that lessees should account for lease and nonlease (typically, service) components
separately (unless they elect the practical expedient) [Emphasis added].” Accordingly, we believe the practical
expedient to not separate was primarily intended for services and other nonlease components transferred over time
and that relate to the lease component (e.g., maintenance of a leased equipment, common area maintenance for a
lease of office space). For nonlease components provided at a point in time such as inventory purchases, we believe
a lessee will frequently conclude that the component is not associated with the lease component because the
lessee usually will be able to redirect the inventory and use it with a different asset, or to resell it in the market.
ALLOCATION OF CONSIDERATION TO LEASE AND NONLEASE COMPONENTS
If a lessee does not elect the practical expedient not to separate for an asset class, once the consideration in the
contract is determined and the components are identified, a lessee allocates the consideration to the lease and
nonlease components on a relative standalone price basis, based on the observable standalone price of each
component. A price is observable if it is the price at which either the lessor or similar suppliers sell similar lease or
nonlease components on a standalone basis.