What do IFRS 5 and US GAAP have in common?
Held for sale classification under IFRS 5 and ASC 360 needs a committed plan, an active program to find a buyer, a reasonable price, availability for immediate sale and an expected sale within one year, with limited exceptions for delays outside the company's control. Both measure held for sale items at the lower of carrying amount and fair value less costs to sell, stop depreciating them, present them separately in the balance sheet, and show a discontinued operation's results, net of tax, as a single amount below continuing operations, with comparatives in the income statement re-presented and EPS for continuing operations shown separately. See IFRS 5 held for sale.
IFRS 5 vs ASC 205-20: what are the differences?
| Area | IFRS 5 | ASC 205-20 and ASC 360 |
|---|---|---|
| What is a discontinued operation? | A component that is a separate major line of business or geographical area, part of a single plan to dispose of one, or a subsidiary bought only to resell | A component whose disposal is a strategic shift with a major effect on operations and results, such as a major line of business, geographical area or equity method investment, or a business held for sale when acquired |
| Prior-year balance sheet | Not re-presented | Assets and liabilities of a discontinued operation re-presented separately for all periods |
| Assets held for distribution to owners, such as a spin-off | Classified as held for distribution, measured at the lower of carrying amount and fair value less costs to distribute, not depreciated | Held and used until distributed, so depreciation continues |
| Equity method investments to be sold | Held for sale, and the equity method stops | Outside the held for sale model; the equity method continues until the sale |
| Gains when fair value later rises | Up to cumulative impairment losses, including IAS 36 losses recognized before the classification | Up to losses recognized under the held for sale guidance only |
| Back to held and used | Lower of the adjusted carrying amount and recoverable amount | Lower of the adjusted carrying amount and fair value |
| Cash flows of a discontinued operation | Net cash flows from operating, investing and financing activities | Either total operating and investing cash flows, or depreciation, capital expenditure and significant noncash items |
| Other disclosures | No specific requirement | Continuing involvement with a discontinued operation, and disposals of individually significant components that are not discontinued operations |
An example: the IFRS 5 division under US GAAP
In the IFRS 5 guide, a company classifies a division as held for sale: property, plant and equipment of CU 900 million, goodwill of 100, inventory of 150 and receivables of 100, less liabilities of 250, a carrying amount of CU 1,000 million against fair value less costs to sell of CU 880 million. The division is a major line of business, so it is a discontinued operation under both frameworks. At the previous year end its assets were CU 1,220 million and its liabilities CU 240 million. All figures are in CU million.
| Item | IFRS 5 | US GAAP |
|---|---|---|
| Loss on classification | 120: goodwill 100, then property, plant and equipment 20 | 120, recognized on the disposal group |
| Current year end: assets and liabilities held for sale | 1,130 and 250 | 1,130 and 250 |
| Previous year end, as shown in the comparatives | Left in the ordinary lines | Assets of discontinued operations 1,220; liabilities 240 |
| If it were a spin-off instead: depreciation for the 6 months before | None | 45 |
The income statement looks the same under both: the division's results for both years in one line, net of tax. The balance sheets differ, because the US GAAP comparatives are restated to isolate the division and the IFRS comparatives are not. Had the division been a smaller business, such as one of several regional brands, it might have been a discontinued operation under IFRS 5 as a separate geographical area, but not under US GAAP if its sale is not a strategic shift with a major effect, or the other way round.
Does IFRS 18 change discontinued operations?
No. From 2027, IFRS 18 classifies income and expenses into operating, investing and financing categories, but discontinued operations stay outside them, in their own line. See the IFRS 18 income statement categories and ASC 360 impairment for the US held for sale rules.
Where to go next
See IFRS vs US GAAP key differences and IFRS 3 vs ASC 805.
Keep going
Our free Excel models work through the examples in these guides, and the comparisons show where IFRS and US GAAP part ways. Every guide names the Chartered Accountant who wrote it and the one who reviewed it.
Questions people ask
What is the difference between IFRS 5 and ASC 205-20?
The held for sale rules are nearly identical, but a discontinued operation is a separate major line of business or geographical area under IFRS 5 and a strategic shift with a major effect under ASC 205-20, and US GAAP re-presents the prior-year balance sheet while IFRS does not.
Is the prior-year balance sheet restated for a discontinued operation?
Under US GAAP, yes: the assets and liabilities of the discontinued operation are shown separately for all periods presented. Under IFRS 5, no.
Are assets awaiting a spin-off held for sale?
Under IFRS 5, they are classified as held for distribution to owners and not depreciated; under US GAAP, they remain held and used, and depreciated, until the spin-off.
What is a strategic shift under ASC 205-20?
A disposal that has, or will have, a major effect on a company's operations and financial results, such as the sale of a major line of business, a major geographical area or a major equity method investment.
Sources
The standards, updates and other documents this guide draws on.
- IFRS Foundation: IFRS 5 Non-current Assets Held for Sale and Discontinued Operations
- FASB Accounting Standards Codification: Subtopic 205-20, Discontinued Operations
- FASB Accounting Standards Codification: Topic 360, Property, Plant, and Equipment
- KPMG US: Assets held for sale and discontinued operations, IFRS Accounting Standards compared to US GAAP
Rules and fees change. If you are reading this long after October 26, 2026, confirm the figures with the source before you rely on them.
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This guide is general information. It is not tax or legal advice for your situation.