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However, the Tax Court said, the nonrecurring nature of the item did not affect the section 404 limits, as the IRS had argued.
Kueppers, national managing partner for risk in the Professional and Regulatory Matters practice at Deloitte & Touche LLP, argued that the cost of 404 compliance is "becoming too much of a focus.
The recent findings of the SEC's Advisory Committee on Smaller Public Companies (ACSPC) indicate that cost and efforts to implement 404 programs far exceeded original SEC estimates of $91,000 per company.
To identify these better approaches, FEI's Committee on Corporate Reporting (CCR) hosted a meeting in Dallas in mid-September, where Section 404 implementation team leaders and their senior managers from some of the nation's largest companies exchanged their successful approaches to compliance.
Of particular note, FERF's report "Sarbanes-Oxley Section 404 Implementation: Practices of Leading Companies," summarized leading practices from the Section 404 discussion session that took place during a meeting of FEI's Committee on Corporate Reporting (CCR), provided useful information for members and regulators alike.
What we have seen is that small companies are using similar methods for 404 compliance that they were using to safeguard company assets.
Securities and Exchange Commission (SEC) rule implementing Section 404 requires management's assessment of ICFR be made with reference to a "suitable, recognized control framework established by a body of experts that followed due-process procedures, including the broad distribution of the framework for public comment.
404 and 415, E's compensation is $48,000 ($50,000 + $10,000 - $8,000 - $4,000).
The second area of focus as a result of the testing of the company's internal controls, as required by adoption of SOX 404, is URI's self-insurance reserves.
Unintended Consequences of Section 404 Implementation
What the stringent requirements of Section 404 did, however, was add layers on to what most had already established.
As financial executives know well, Sarbanes-Oxley Section 404 calls for documented proof that a company has an adequate internal control structure and procedures for financial reporting, as well as assessment of the effectiveness of these same areas.
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- 401(k) plan
- 401(k) Plans
- 401-k plan
- 401-k plan
- 401k Plan
- 401k Plans
- 4029 Form
- 4029 Forms
- 403(b) Plan
- 403(b) Plans
- 403b Plan
- 403b Plans
- 404 Error
- 404 Error
- 40bit color
- 40bit colour
- 40G Ethernet
- 40th Infantry Division
- 40th millenium BC
- 40th millennium BC
- 40th President of the United States