Rückstellungen nach § 249 HGB und ihre Entsprechungen in den US-GAAP und IAS

Group accounting in Germany and in the E.U. is presently going through a phase of internationalization. The milestones of this development were the introduction of Section 292a in the Commercial Code on April 20, 1998 and the E.U regulation 1606/2002 on July 19, 2002. Using international comparative law, Daniel D. Rothoeft does a systematic study of how the facts of a case which are to be subsumed under Section 249 can be dealt with according to the U.S. GAAP and the IAS/IFRS. The results of the study are illustrated using examples from civil law and public law and then summarized. These summaries form the basis for an examination of the extent to which the three structures (HGB or Commercial Code, U.S. GAAP and the IAS) actually correspond to one another.