Mirror image accounting applies to the extent that the terms of the indemnification arrangement fully cover the related exposure.
Where the indemnification covers the implied interest cost associated with spreading the deduction over a longer period, the indemnification asset would not equal the related liability.
The indemnification covers any tax exposure that exceeds a specified dollar amount.
There may be scenarios where the terms of the indemnification fully cover the tax exposure, but the related classification or measurement may differ, such as:
In this situation, mirror image accounting may apply (assuming that interest and penalties are covered by the indemnification); however, the indemnification asset would mirror the total of the tax liability and the related interest and penalty accruals.
There may also be scenarios where the seller provides a blanket indemnification for taxes owed in prior years, but no specific tax positions are reserved.
If the seller indemnifies the buyer for the related tax exposure, the buyer would record a $20 indemnification asset even though no liability is presented.
In connection with the implementation of ASC 740 by public investment funds, certain investment management businesses approached the SEC staff for guidance on accounting for potential indemnification provided by a fund's advisor.