2 Long-lived assets to be held and used
Financial reporting developments Impairment or disposal of long-lived assets | 19
Determining whether cash flows are directly associated and are expected to arise as a direct result of the
use and eventual disposition of the long-lived asset (group) likely will be a very subjective determination.
ASC 360-10 provides no guidance or examples of situations that illustrate what it means by “directly
associated.” Therefore, we believe that reasonable determinations should be made. For example, if a
trucking entity owns its trucks and determines that a truck represents the lowest identifiable cash flows,
the entity would likely only include cash flows generated from the freight the particular truck carries,
along with cash outflows such as gas, insurance, tolls, maintenance and the salary and benefits of the
truck driver. Indirect cash outflows of support personnel such as schedulers and management likely would
not be included in those cash flow estimates because they are not directly related to the use of the truck.
Using an entity’s own assumptions when estimating cash flows for a recoverability test differs from the
process an entity undertakes in measuring fair value which is based on market participant assumptions
(see section 2.4 for information on fair value determinations). For example, if a plant is presently being
used to manufacture wall fasteners and it is the entity’s intention to continue to utilize the plant for that
purpose, even though a third party would likely use the plant to manufacture paint, the estimated cash
flows used to test the plant for recoverability would still be based upon the continued manufacturing of
wall fasteners. If the cash flow estimates used in a recoverability test assume an entity will dispose of the
long-lived asset before the end of its estimated useful life, those cash flow estimates would assume the
proceeds from the sale will be based on its existing use (e.g., the plant will not be converted by the entity
into a paint manufacturing facility). An entity’s own assumptions are used in the Step 2 testing of a long-
lived asset (group) for recoverability because a recoverability test is not a valuation; rather, it is a test to
determine whether the entity will recover the cost of the long-lived asset.
The FASB did not establish specific limits on the assumptions used to generate cash flow estimates, such
as requiring the use of current prices and volumes because those assumptions may be inconsistent with
the entity’s own assumptions about its use of the long-lived asset. Thus, if an entity has a reasonable
basis to assume that prices or volume will increase from current levels (e.g., current economic and
industry trends indicate an increase in demand, or the futures market indicates that prices are likely to
increase), it is appropriate to reflect such increases in the cash flow estimates. However, the assumptions
used must be reasonable in relation to the assumptions used in developing other information used by the
entity for comparable periods, such as internal budgets and projections and accruals related to incentive
compensation plans. In addition, entities may not use information in assessing the recoverability of long-
lived assets that is inconsistent with that used for other accounting purposes (e.g., assessing the
recoverability of deferred tax assets). The SEC staff also has challenged instances where cash flow
projections were inconsistent with those provided to analysts or other third parties.
The process of objectively verifying the evidence supporting cash flow estimates used in impairment
evaluations will be difficult, if not impossible, especially when cash flows must be estimated for an
extended period of time (e.g., estimating cash flows for a building that has a useful life of 30 years)
because very few long-term forecasts have an objective basis beyond a few years. The FASB’s approach
will often require entities to go well beyond the period that auditors are permitted to report on a forecast
made pursuant to the AICPA’s Guide for Prospective Information that indicates that it “ordinarily would be
difficult to establish that a reasonably objective basis exists for a financial forecast extending beyond
three to five years.” Accordingly, estimating future undiscounted cash flows will require a great deal of
judgment and, in most cases, will be extremely subjective. Nonetheless, care and consideration must be
given to the assumptions used and should be supported by available evidence, if possible. In addition,
entities should be particularly wary of projections that indicate dramatic increases in future cash flows
(e.g., three years of flat cash flows, then a 10% increase per year, for the next ten years).