1. Do you believe Allergan’s financial information in its press

1. Do you believe Allergan’s financial information in its press release is useful? Why or why not?
2. Do you believe this kind of information should be subject to audit procedures? If so, what procedures should be used? If not, why not?
3. Do you believe the financial and non-financial information provided by Allergan in its press release is veiled attempt at earnings management? Explain.
4. Does the reconciliation shed light on the usefulness and understandability of the non-GAAP numbers? Explain.
5. Look at each item included in the reconciliation and briefly discuss whether you think each one should or should not be included in reconciliation from GAAP to non-GAAP.


Exhibit 1 presents the fourth quarter press release of Allergan. Allergan is a global pharmaceutical company and a leader in a new industry model – Growth Pharma. Allergan’s product lines include Botox, Juvederm, Latisse, Namenda, and Restasis. Exhibit 2 presents the reconciliation from GAAP to non-GAAP income that was included with the release.

Over the years, Allergan has had many disagreements with the SEC about the presentation of non-GAAP metrics in their financial reports and press releases. Allergan’s responses to SEC staff comments has been to emphasize that its performance measures “are useful to both management and investors in assessing current performance and future operations.” Moreover, Allergan contended in its response that “analysts for our industry group base their third-party consensus estimates on non-GAAP earnings per share metrics.”

GAAP
Generally Accepted Accounting Principles (GAAP) is the accounting standard adopted by the U.S. Securities and Exchange Commission (SEC). While the SEC previously stated that it intends to move from U.S. GAAP to the International Financial Reporting Standards (IFRS), the...

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