Kevin Briggs

I have two specific experiences of working with US-quoted companies, Ultralife Batteries (UK) Ltd and Bookham Technology plc. In addition I have helped Sainsbury's IT procurement team find their way through US revenue recognition rules (SOP 97-2, SFAC 5 and SAB 101). The main challenges that I found with these companies were as follows:

• using US-familiar terms when speaking with US executives, eg inventory and not stock, receivables rather than debtors. Nowadays, the risk of misunderstanding terms is diminished by common terms usage between US GAAP and International Financial Accounting Standards (IFRS).

• explaining business concepts that are different (UK business interruption insurance is fundamentally different to the US version as is the UK's ability to impose non-compete agreements on existing staff contracts for when they leave employment)

• certain, but not many accounting policy differences, such as deferred tax, different tax consequences concerning capitalisation of loans, the tax treatment of distributions and the tax consequences of transfer pricing goods bought from the US for onward sale into the European Union

• the accounting treatment of transactions that were not covered by specific US Generally Accepted Accounting Practice, notably the treatment of assets destroyed in Ultralife Batteries' 3 fires and the associated insurance proceeds

• the implementation of internal controls and procedures to ensure that the business did not have compliance issues over revenue recognition (US accounting standard FASB 5), particularly at Bookham Technology and in support of procurement's negotiations with US quoted software companies at Sainsbury's

• a US owner making a public offering and making representations about the UK company in its 10Q and 10K returns. I was responsible for writing those aspects of those reports relating to the UK and of the 1998 public offering (Ultralife Batteries).

• ensuring that a US holding company did not fall foul of the UK's Companies Acts regulations. US companies have little concept of a subsidiary having a separate legal status and that company secretarial regulations have to be adhered to.

Please note that Canadian quoted companies have to adhere to Canadian Generally Accepted Accounting Practice, which is very similar to that of the US.