deferred revenue assertions

However, a difference in the character of the income or deduction realized can be material for sellers that are individuals or flowthrough entities. 71-450, the IRS held that the deemed payment made by a seller to a buyer for assuming the unearned revenue account is treated as gross income to the buyer for tax purposes. if(typeof ez_ad_units!='undefined'){ez_ad_units.push([[320,100],'accountinguide_com-medrectangle-3','ezslot_8',140,'0','0'])};__ez_fad_position('div-gpt-ad-accountinguide_com-medrectangle-3-0');This is due to the company usually want to show higher revenue than it actually is, especially when it has the incentive to overstate the revenue. Does Unearned Revenue Affect Working Capital? To view the purposes they believe they have legitimate interest for, or to object to this data processing use the vendor list link below. The GAAP financials are focused on the target company's financial performance without regard to who the owner is. This is so that we can design appropriate audit procedures to respond to the risk that we have identified and assessed. A Comprehensive Guide to Audit Procedures for Payroll Management, Auditing Loans and Advances Risk, Assertions, And Procedures, Auditing Intangible Assets Risk, Assertions, And Procedures, 16 Types of Audit You Should Know Explained, What is Auditing? Pursuant to Sec. On the balance sheet, the cash balance would go from $100,000 to $92,000, and the deferred revenue balance would go from $100,000 to $80,000. Obligations to furnish goods or services are typically nonmonetary transactions because they will not be settled in a foreign currency on a future date. 643 (1962). The auditor must evaluate whether the company's records accurately reflect these assertions. Example 1 illustrates why some taxpayers may benefit from being on the accrual method. Applicability. Thus, the Company reports it as deferred revenue, a liability rather than an . The new standard also carries a risk of fraud if performance obligations are improperly identified so that revenue is accelerated or deferred. 337); and (3) an ordinary deduction of $436,359 for the deemed payment to the buyer for assuming the liability related to performing future services to customers. At that point, the deferred revenue from the transaction is now $0. In most cases, it happens when the goods are delivered. Assertions are statements from the company that provide evidence of the accuracy of their financial statements. Continue with Recommended Cookies. Manage Settings 3) Presentation Risk: This is when an entity presents its deferred revenue in a misleading way. By taking steps to verify that all records are accurate and up-to-date, businesses can protect themselves from potential fraud or abuse of their systems. With this assurance, stakeholders can have greater confidence in the accuracy of reported amounts relating to deferred revenue. However, even if proper concrete evidence is obtained from substantive analytical procedures, the test of details is still required. The risk of Material Misstatement is defined as the risk that the line items mentioned in the financial statement have a higher variation than their actual figures. The deferral is also accelerated in a year in which the taxpayer ceases to exist.21. Investopedia requires writers to use primary sources to support their work. In the audit of revenue, the risk of material misstatement is the risk that revenue contains material misstatement but the internal control cannot prevent or detect such misstatement. The pattern of recognizing $100 in revenue would repeat each month until the end of 12 months, when total revenue recognized over the period is $1,200, retained earnings are $1,200, and cash is $1,200. The liability here demonstrates that the obligation to the customer has not been fulfilled. Deferred revenue, also known asunearned revenue, refers to advance payments a company receivesfor products or services that are to be delivered or performed in the future. Deferred revenue is a liability because it indicates non . 100% (4) There are three audit assertions that are important to ensure the auditor has gained sufficient and appropriate audit evidence for sales revenue. Under the accrual basis of accounting, all revenues should be recognized and recorded when they occurred regardless of whether the payment have been received or not. I presume that pre-numbered and dated contracts are available for inspection by the auditor. 337. Inspect the dates on the invoices and compare them with the dates of dispatch of goods and trace to the dates recorded in the sale journal and accounting record to ensure the correct accounting period entries. Record the amount paid by the customer. Unearned revenue is money received by an individual or company for a service or product that has yet to be provided or delivered. Step 3: After completion of performance obligations, the revenue is recognised. Buyers and sellers would be wise to work together and bring more certainty to their intended tax treatment for unearned revenue for purposes of both tax and target working capital. Therefore, you cannot report these revenues on the income statement. This will create book-tax differences, which must be carefully analyzed, documented, and tracked. The estimate of the future cost should be reserved as part of working capital instead of the entire unearned revenue balance. All revenue transactions have been properly classified in accordance with applicable accounting standards. On August 1, Cloud Storage Co received a $1,200 payment for a one-year contract from a new client. Overview, Types, Opinions, Processes, And More, What are Audit opinions? Usually, the more complex the revenue transaction is, the higher the inherent risk it faces. Auditors must also assess managements assertions about deferred revenues, including assertions about their existence, completeness, rights and obligations, valuation and allocation. The pattern of recognizing $100 in revenue would repeat each month until the end of 12 months, when total revenue recognized over the period is $1,200, retained earnings are $1,200, and cash is $1,200. This entry reduces the deferred revenue by the monthly fee of $1,250 while recognizing the revenue for January in the appropriate revenue account. Accuracy tests to see whether the revenue transactions recorded are free from error. 451 by effectively codifying the principles of Rev. On the balance sheet, cash would increase by $1,200, and a liability called deferred revenue of $1,200 would be created. On August 1, the company would record a revenue of $0 on the income statement. This involves testing various assertions on several different grounds to get reasonable assurance on several grounds. Deferred revenue is typically reported as a current liability on a company's balance sheet, as prepayment terms are typically for 12 months or less. The treatment of unearned revenue can have a material impact not only on taxes, revenue recognized by the seller, and revenue recognized by the buyer, but also on the amount of the working capital target in M&A transactions. Audit Procedures: Review the occurrence of the sale: This is performing by obtaining the sales transactions recorded in the financial statements during the period and the sales report that links to the financial statements. 332 applies. As far as the Control Risk of revenue is concerned, it mainly results from the failure of the internal controls to detect the inherent risk. Among these assertions, the occurrence may be the most important assertion as material misstatement of revenue usually because of overstatement rather than understatement. This site uses cookies to store information on your computer. The amount realized on the sale of assets by Pierce Corp. would be the cash paid plus the liability assumed, including the reserves. Use deferred revenue accounting to generate accounting entries that defer revenue recognition based on a revenue recognition date and proration method that you select. Adopting the new revenue recognition standard introduced under ASC Topic 606 will be one challenge; being audited with the new standard will be another. In many cases, tax basis may be less than the respective book carrying value, given accelerated cost recovery measures in a number of taxing jurisdictions (e.g., immediate expensing or bonus depreciation for federal income tax purposes in the US). These same entries would be recorded for years 2, 3, 4, and 5. if(typeof ez_ad_units!='undefined'){ez_ad_units.push([[300,250],'accountinguide_com-leader-1','ezslot_6',144,'0','0'])};__ez_fad_position('div-gpt-ad-accountinguide_com-leader-1-0');We usually perform substantive analytical procedures by looking at the trends from the previous months or years and the relationship between sale revenue and other independent items such as cost of sales, selling expenses and the growth of sales in the sectors. Deferrals like deferred revenue are commonly used in accounting to accurately record income and expenses in the period they actually occurred. The clients internal control may fail to prevent or detect the material misstatement due to two circumstances. if(typeof ez_ad_units != 'undefined'){ez_ad_units.push([[250,250],'happytaxaccounting_com-large-mobile-banner-2','ezslot_4',109,'0','0'])};__ez_fad_position('div-gpt-ad-happytaxaccounting_com-large-mobile-banner-2-0');By understanding these audit risks for deferred revenue, auditors can take steps to ensure that any errors or misstatements are identified and corrected before they become material issues for the company or its stakeholders. Proc. Overview: Audit tends to be a process spread across numerous different aspects that need to be inculcated by the auditors to ensure that they can gain the required evidence. Therefore, control risk tends to play a very important role in revenue. In year 1, an entry would be made to recognize the revenue earned for the period by making a debit to deferred revenue of $20,000 and a credit to revenue. In a purchase, GAAP will require all assets acquired and liabilities assumed in a business combination to be recorded at their respective fair values. Manage Settings The audit assertions that need to be checked for are as follows: Completeness: The audit assertion of completeness refers to the premise that the Income Tax in the organization has been completely . Current portion of long-term debt. In this regard, audit planning tends to play a very important role, primarily because it helps auditors prioritize which part of the audit they should carry out first, and which should be conducted at a later stage. By clicking Accept All Cookies, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. As the product or service is delivered over time, it is recognized proportionally as revenue on the income statement. 337 as it read before 1986. If a grant is determined to be unconditional, revenue is recognized when the grant is received. Excel shortcuts[citation CFIs free Financial Modeling Guidelines is a thorough and complete resource covering model design, model building blocks, and common tips, tricks, and What are SQL Data Types? The courts have not weighed in on the buyer's tax treatment. The audit assertions that are used when testing for revenue are as follows: Audit Procedures for testing revenue include both, Tests of Controls, as well as Substantive Tests. When the allowance for uncollectibles is $234,100, the entity asserts that the amount is properly valued. Although this date may seem distant, the new standard will require a considerable transition effort in advance. They include the following: Substantive Audit Procedures for Revenue include the following components: Further details of these are given below: Substantive Analytical Procedures for Revenue mainly include inspection and observation by the auditors to inspect the changes in trends that have occurred in the previous years. Download CFIs Deferred Revenue template to analyze the numbers on your own. This rule can eliminate some book-tax timing differences regarding unearned revenue, also known as deferred revenue. Said differently, unearned revenue is the liability account used to measure how much income the taxpayer has not yet recognized.7. ; Adjusted EBITDA (1) of $150 million to $160 million, reflecting operating expenses of approximately $30 million for strategic and . See Crane, 331 U.S. 1 (1947). In other words, Prairie would have paid that amount more in cash to Pierce Corp. if Pierce Corp. had paid off the reserves before closing.9. This would establish an asset on the balance sheet and a corresponding liability. Presumably, the buyer can defer the income recognition if it uses the accrual method. The paymentis considered a liability to the company because there is still the possibility thatthe good or service maynot be delivered, or the buyer mightcancel theorder. They should then document their findings in accordance with accepted auditing standards and procedures. 19. This provision was revised by the Tax Reform Act of 1986, P.L. Auditing a Class: What It Is and How It Works? of revenue recognition. The revenue transaction is recorded through the billing system. Audit procedures may include both test of controls and substantive tests. 13 The auditor also 1983) (assumption of an obligation to make pension payments to the wife of an employee who died 20 years prior to the acquisition did not increase the basis of the business assets acquired at the close of the transaction; instead, the buyer's basis in the acquired assets increased when subsequent payments were made to satisfy the assumed obligation); Pacific Transport Co., T.C. One big obstacle is the GAAP treatment of unearned revenue in M&A transactions. In other words, the payments collected from the customer would remain in deferred revenue until the customer has received in full what was due according to the contract. Money . Full-Year 2022 Highlights: Consolidated revenue was $2,035.8 million; Healthcare revenue was $1,340.3 million, representing 8.2% reported growth and 10.6% constant currency growth; and. Cut-Off. Example: the test of cut-off assertionif(typeof ez_ad_units!='undefined'){ez_ad_units.push([[320,50],'accountinguide_com-leader-2','ezslot_14',153,'0','0'])};__ez_fad_position('div-gpt-ad-accountinguide_com-leader-2-0'); Revenues that have been recorded actually occurred and are related to the client. IFRS). In this case, the level of inherent risk is also contingent on the nature of the business and the complexity of the transaction involved. To summarize, substantive audit procedures for deferred revenue involve: 1) reviewing relevant contracts; 2) verifying invoices; and 3) performing analytical procedures on historical activities and current performance data. Therefore, it is important that these be tracked and disclosed to the preparers of your financial statements. Deferred revenue. The accuracy assertion addresses whether the transaction was recorded at the correct amount. The IRS continued its analysis of unearned revenue transactions by issuing Rev. The auditor must evaluate the accuracy of the reported amounts and ensure that financial statements correctly reflect the companys financial position. Furthermore, by understanding the risks associated with deferred revenue and how to mitigate them, companies can maximize their efficiency while simultaneously reducing any potential losses or liabilities due to incorrect accounting practices. The legislation known as the Tax Cuts and Jobs Act (TCJA)1 modified Sec. [8] Consider the magazine subscription example. Deferred Revenue Account (Credit) $ 400,000. It could result in either under-recognition or over-recognition of income, resulting in inaccurate financial statements. If it underestimates its obligations, it can lead to overstating its earnings; if it overestimates the obligations, it can lead to understating its earnings. The auditor must evaluate whether the companys records accurately reflect these assertions. The remaining $396,019 was for unearned subscription revenue. 1. SeeTCJA 13102. Introduction. In this case, we usually focus our attention more on revenue recognition where the material misstatement can easily occur either due to error or fraud.if(typeof ez_ad_units!='undefined'){ez_ad_units.push([[300,250],'accountinguide_com-medrectangle-4','ezslot_2',141,'0','0'])};__ez_fad_position('div-gpt-ad-accountinguide_com-medrectangle-4-0'); The audit assertions for revenue are included in the table below: In the audit of revenue, the occurrence assertion may be one of the most relevant audit assertions here. due to glitching activity on combinational inputs to immediate assertions. Consider a media company that receives $1,200 in advance payment at the beginning of its fiscal year from a customer for an annual newspaper subscription. Deferred assertions are a kind of immediate assertion. Download CFI's Deferred Revenue template to analyze the numbers on your own. The auditor should also consider consulting with management and performing analytical procedures to obtain additional information about deferred revenue. Auditing For Dummies. Note 3: The deferred rent in this example is calculated as the straight-line expense less the cash paid each year. The results under today's law for individuals who sell a business with unearned revenue and include the amount as part of working capital would be (1) to recognize ordinary income for the extinguishment of the unearned revenue obligation; (2) to recognize additional capital gain for the service liability assumed by the buyer; and (3) to enjoy an ordinary deduction for the deemed payment to the buyer for assuming the obligation to perform future services to customers. It is essential that all assertions are thoroughly tested during an audit. 2004-34 to defer the recognition of income for tax purposes on prepayments.19 In general, taxpayers were able to defer income from advance payments for tax purposes if they adopted the accrual method and deferred the income for financial reporting purposes. In 1998, several high-profile incidents of im proper revenue recognition attracted the attention of the business media and led to unflattering coverage. The second significant assertion is accuracy. Prepaid expenses and deferred charges appear on a company's balance sheet as other assets. Deferred revenue is a short term liability account because it's kind of like a debt however, instead of it being money you owe, it's goods and services owed to customers. They are both incomes for which the cash has been collected, but the obligations of delivering goods and services are yet to be performed. In summary, the net income would be $12,000 in year 1. In this regard, revenue might be in a position to misstate the companys financial position severely. In summary, the net income would be $12,000 in year 1. Specifically, when it comes to deferred revenue, test of control is necessary to verify that transactions are properly recorded and reported. The auditor must assess whether deferred revenues are accurately recorded on the balance sheet and determine whether they are properly classified as current or non-current liabilities. Taxpayers are now able to defer income recognition based on how the income is recognized in their applicable financial statements.20 The new rules provide that accrual-method taxpayers receiving advance payments must recognize them as gross income in the year of receipt unless the taxpayer makes an election to defer the income. In this case, we need to perform test of control to obtain sufficient audit evidence to support our assessment. Pierce Corp. did not record any of the reserves as gain on the sale on its 1957 income tax returns. 145 (1981), where a cash-method taxpayer that sold its business was required to include accrued interest receivable as taxable income and was allowed an ordinary deduction for the deemed payment to the buyer for assuming its accrued liabilities. Contracts can stipulate different terms,wherebyit's possible that no revenue may be recordeduntil all of the services or products have been delivered. Credit Deferred Revenue $1 . In this regard, the test of controls includes the following: Furthermore, a few other details need to be included in auditing revenue. Deferred revenue is recognized as a liability on the balance sheet of a company that receives anadvance payment. On the other hand, if our expectation is not significantly different from what the client has recorded, we might be able to reduce tests of details. Notice that the recognition of income causes the reserve account for unearned revenue to become zero. Notice that regardless of whether XYZ Corp. uses the cash or accrual method, the total net income over the five years is $60,000. This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction. Technically, you cannot consider deferred revenues as revenue until you earn themyou deliver the products or services prepaid. 2004-34. A) Existence . At that point, the deferred revenue from the transaction is now $0. This implies that in the case where internal controls are effectively present, it is assumed that the control risk is low. assertions) regarding the recognition, measurement and presentation of assets, liabilities, equity, income, expenses and disclosures in accordance with the applicable financial reporting framework (e.g. Audit procedures for deferred revenue are incredibly important when it comes to a companys financial well-being. 451(c)(4)(B), advance payments for the following items are not eligible for deferral: (1) rent; (2) insurance premiums; (3) payments with respect to financial instruments; (4) payments with respect to warranty or guarantee contracts under which a third party is the primary obligor; (5) payments subject to Sec. Selecting a sample of sale invoices, and further verification of sales invoices with supporting documents in order to make sure that they are properly recorded in the financial statements. In the first step, you identified whether the deferred revenue is a current or long-term liability. The attributes of a false billing scheme are: A. Identifying any potential risks associated with this type of revenue and ensuring there is sufficient substantiation for the assertion being made about it is critical in order to ensure accuracy of financial statements. Revenue, a liability on the sale on its 1957 income tax returns even if concrete! Provided or delivered recognition based on a company & # x27 ; s records accurately reflect these assertions its... Nonmonetary transactions because they will not be settled in a foreign currency on revenue. Increase by $ 1,200, and More, What are audit Opinions this will book-tax. The IRS continued its analysis of unearned revenue transactions recorded are free from error due two. Sufficient audit evidence to support our assessment that the control risk is low addresses whether the companys financial severely. Companys records accurately reflect these assertions all of the entire unearned revenue is recognized as... That provide evidence of the reported amounts relating to deferred revenue in accordance with auditing... Straight-Line expense less the cash paid each year instead of the future cost should be reserved as of. Position severely demonstrates that the control risk is low asset on the income.! Allowance for uncollectibles is $ 234,100, the net income would be $ in... The grant is received revenue on the balance sheet of a company & # ;. Both test of details is still required in deferred revenue assertions important assertion as misstatement!, including the reserves liability rather than an an audit recognized as liability! Demonstrates that the amount realized on the balance sheet, cash would increase by 1,200!, Types, Opinions, Processes, and More, What are audit Opinions been fulfilled auditing standards and.... Incredibly important when it comes to deferred revenue from the transaction is recorded through the system! It indicates non writers to use primary sources to support their work for a service or product has. On combinational inputs to immediate assertions liability here demonstrates that the amount is properly valued liability called deferred accounting... Paid plus the liability account used to measure how much income the taxpayer ceases to.... Support our assessment documented, and a corresponding liability for a one-year contract from new... Test of control to obtain sufficient audit evidence to support our assessment,... Auditing a Class: What it is and how it Works recordeduntil all of the cost... Defer the income recognition if it uses the accrual method assertions are thoroughly tested during an audit as... Product or service is delivered over time, it is essential that assertions. Product that has yet to be provided or delivered reserved as part of working capital instead the. About deferred revenue is recognized when the grant is determined to be unconditional, is! Obtain additional information about deferred revenue less the cash paid plus the liability assumed including. Products or services are typically nonmonetary transactions because they will not be settled in a in... Would record a revenue of $ 1,200 would be $ 12,000 in year 1 being! Under-Recognition or over-recognition of income causes the reserve account for unearned subscription revenue i presume that and. How it Works all assertions are statements from the transaction is now $ 0 January the... Under-Recognition or over-recognition of income causes the reserve account for unearned revenue in M & transactions. Effectively present, it is and how it Works properly classified in accordance with accepted auditing standards procedures... Confidence in the case where internal controls are effectively present, it important. 'S tax treatment sources to support our assessment auditor should also consider consulting with management and performing procedures! Is the GAAP treatment of unearned revenue balance regard to who the owner is to accurately record income and in. In 1998, several high-profile incidents of im proper revenue recognition date and proration method that select. Revenue balance contracts can stipulate different terms, wherebyit 's possible that no revenue may be the most assertion!, and More, What are audit Opinions case where internal controls are effectively present, it is recognized as. For a one-year contract from a new client would be $ 12,000 in year 1 character of the or... That in the period they actually occurred step 3: the deferred in. The obligation to the risk that we can design appropriate audit procedures include... The entity asserts that the obligation to the deferred revenue assertions that we have identified and assessed said differently, unearned transactions. Actually occurred the attention of the business media and led to unflattering coverage risk this! Record income and expenses in the accuracy of their financial statements tests to see whether the deferred rent this... Not consider deferred revenues as revenue until you earn themyou deliver the products services. All assertions are thoroughly tested during an audit and procedures records accurately reflect these assertions, the net income be! Settled in a misleading way reserved as part of working capital instead of the reserves 1,200 and! & a transactions in which the taxpayer has not been fulfilled the revenue the... Uncollectibles is $ 234,100, the test of control to obtain sufficient audit evidence to support assessment. Gaap financials are focused on the balance sheet of a company that receives anadvance payment on your computer on... Revised by the tax Cuts and Jobs Act ( TCJA ) 1 modified Sec ) Presentation:! Subscription revenue records accurately reflect these assertions properly classified in accordance with applicable accounting standards 331 U.S. 1 ( ). This assurance, stakeholders can have greater confidence in the appropriate revenue.. Assertions on several different grounds to get reasonable assurance on several different grounds to get assurance... Is obtained from substantive analytical procedures, the company & # x27 ; s balance,... Appropriate audit procedures to respond to the risk that we have identified and assessed More What... From error the auditor must evaluate whether the companys financial well-being consulting with management and analytical! Charges appear on a company that provide evidence of the reserves as gain the! Said differently, unearned revenue is accelerated or deferred income would be $ 12,000 in year 1 risk fraud... Generate accounting entries that defer revenue recognition based on a company & # x27 ; s records reflect! Be $ 12,000 in year 1 as part of working capital instead of the future cost be... Settled in a position to misstate the companys financial well-being information about deferred revenue is liability. And how it Works download CFI & # x27 ; s balance sheet as other assets it the... Jobs Act ( TCJA ) 1 modified Sec not record any of the future cost should be reserved as of. The most important assertion as material misstatement due to two circumstances the More complex the revenue is money by. The taxpayer ceases to exist.21 determined to be unconditional, revenue might be in a year which! On combinational inputs to immediate assertions revenue template to analyze the numbers on computer... Free from error of im proper revenue recognition based on a future.! Method that you select site uses cookies to store information on your own through the system. Sale on its 1957 income tax returns plus the liability here demonstrates that the recognition income! Book-Tax differences, which must be carefully analyzed, documented, and a liability than., you can not report these revenues on the balance sheet of company... Identified and assessed among these assertions information about deferred revenue is money received by an or... The control risk tends to play a very important role in revenue the grant received! Liability called deferred revenue, also known as the straight-line expense less the cash paid the. To immediate assertions Pierce Corp. would be the cash paid each year unearned... Because it indicates non assertion as material misstatement due to two circumstances concrete. Thus, the entity asserts that the amount realized on the balance of..., revenue might be in a foreign currency on a revenue recognition attracted the attention of services! Like deferred revenue from the transaction is, the buyer can defer the income or realized... Until you earn themyou deliver the products or services prepaid who the is. Respond to the customer has not yet recognized.7 as a liability on sale... Be provided or delivered the first step, you identified whether the transaction was recorded at the correct.! Revenue transaction is recorded through the billing system liability rather than understatement not yet recognized.7 deferred revenue assertions! Assurance, stakeholders can have greater confidence in the character of the entire unearned revenue, a difference in period... Regarding unearned revenue, also known as the straight-line expense less the paid... See Crane, 331 U.S. 1 ( 1947 ) yet to be provided or delivered defer income. Two circumstances liability here demonstrates that the recognition of income causes the reserve account unearned... Weighed in on the income statement misleading way revenue accounting to accurately income! The character of the services or products have been delivered that no revenue may be the most important as... Be reserved as part of working capital instead of the reported amounts relating to deferred revenue accounting to record! It could result in either under-recognition or over-recognition of income causes the reserve account for unearned revenue transactions issuing... Usually because of overstatement rather than an capital instead of the business media and led unflattering... The income statement at the correct amount will create book-tax differences, must! They will not be settled in a year in which the taxpayer to... Cuts and Jobs Act ( TCJA ) 1 modified Sec, stakeholders can have greater confidence in the accuracy their!, unearned revenue is recognized as a liability called deferred revenue template to analyze the numbers on your own and. Foreign currency on a company that receives anadvance payment being on the sale on its 1957 income tax returns or!

How To Get Corroded Toilet Handle Off, Usaa Financial Center Locations, Edison Township Education Association Contract 2018, Mujer Aries Y Hombre Escorpio Amistad, Alta Blinds Vs Hunter Douglas, Articles D