COVID-19: Accounting for Lease Concessions

Article written by:
Dustin Minton, CPA, MBA
   Director, Assurance & Business Advisory Services

In April 2020, during the midst of the pandemic, the Financial Accounting Standards Board (FASB) issued a Staff Q&A discussing how lease concessions being made as a direct result of COVID-19 could be treated under Topic 842 and Topic 840.  Certainly, this was important for public companies to understand and report on for their quarterly filings; however, many private companies, especially restaurants, have been busy focusing on keeping their business alive and responding to the gauntlet of challenges facing them in a remote work environment and often with fewer employees.  Let’s start off with the Q&A as it provides good news for both public and private companies on how to apply a practical approach to the lease concessions provided during this pandemic.

Most private companies have not adopted Topic 842 as this was deferred until fiscal years beginning after December 15, 2021, which is the 2022 calendar year for most companies. Several private companies continue to report under Topic 840.  Luckily the approach under 842 and 840 is similar to this Staff Q&A as it relates to lease modifications.  As you know, lease accounting can get complicated especially when modifications come into play.  With the onslaught of lease concessions being offered as a direct result of COVID-19 in the form of deferred rent or rent abatement (free rent), the FASB recognized that the time needed to analyze leases and properly account for them under lease modification guidance was overly burdensome.  As a result, the FASB has allowed a practical approach to accounting for lease concessions.

Election criteria

The FASB has allowed for all companies to make an election to assume existing lease contracts provided enforceable rights and obligations for lease concessions to allow these concessions to not be treated as a lease modification.  It is important to note the following:

• The lease concession has to be a direct result of COVID-19 to be eligible for this election.
• The lease concession does not result in a substantial increase in the rights of the lessor or the obligations of the lessee. In other words, the remaining lease obligation has stayed the same or decreased even if the time period has been extended.

What method should I consider?

The FASB provided two acceptable methods as examples to account for these lease concessions.  The FASB expects there will be multiple ways to account for the deferrals.  Below reflects the methods from a lessee perspective.  The lessor perspective would be similar going the other way as rental income.

Method	Journal Entry	Financial Statement Impact
1.  Account for the concession as if no changes to the lease contract were made.	Dr. Straight-line rent expense Dr./Cr. Deferred rent Cr. Accounts payable	There is no change to the P&L impact Rent expense continues to be recognized Accounts payable increases until such time as rent is paid
2.  Account for the deferred payment as variable lease payments	None Rent is expensed when paid	No rent expense or accrued expense is recorded

 

So which method should you choose?

 

Method	Pros	Cons
1.  Account for the concession as if no changes to the lease contract were made.	Deferred rent schedules remain the same Expense is recognized in a down year already	Bottom line will be lower as expense is recognized with lower revenues for the same periods Unfavorable impact to your debt covenants as expense has been recognized with less revenues for the same periods
2.  Account for the deferred payment as variable lease payments	Less rent expense will be recognized, dependent upon when those deferred payments become payable Favorable impact to your debt covenants unless your lender has a special add back for deferred rent	Deferred rent schedule will need to be adjusted for lack of rent recognized for applicable months Additional rent will be recognized in the year when paid

 

You can see there are pros and cons to each and you will have to decide which is best for your company, considering that the above two example methods are not the only options to consider.

What do I need to disclose?

Lessors should provide disclosures about material concessions granted.  Lessees should provide disclosures related to the material concessions received.  This will enable the user to better understand the nature and financial impact related to COVID-19.

What if I report under the income tax basis of accounting?

There is an important distinction between US GAAP and income tax basis of accounting.  The above guidance relates only to those financial statements reported under US GAAP.  For those reporting under the income tax basis of accounting, typically, you can be either on the cash or accrual method of accounting. If you are on the cash method, generally speaking, only rent paid within your tax year would be deductible. If you are an accrual basis taxpayer, in general, you are beheld to the economic performance rules. Those standards, along with exceptions, address the timing for when expenses are deducted. Each situation is different in navigating these rules, and we recommend consulting with your tax advisor for proper treatment based on your facts and circumstances.

If you have any questions on lease accounting, please reach out to Dustin Minton.

 

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