May 23, 2000

Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street NW
Washington D.C. 20549-0609

RE: File No. S7-04-00, Concepts Release: "International Accounting Standards"

Dear Sir:

I am writing in response to the Commission's request for comments on the Concepts release International Accounting Standards, dated February 16, 2000. As this letter will become a part of the public record, I have included information about my professional qualification as an addendum to the letter. The views expressed in this letter are my own and cannot be attributed to my employers or any organization to which I belong. My purpose in writing is to provide you with a view from my role as a knowledgeable professional who has been involved in the analysis, preparation, research and use of financial statements.

I have chosen to address those issues that I believe are of most importance and not to answer the twenty-six individual questions you specify. My answer to most of the questions is implicit in the substance of the comments reflected in this letter.

The Commission should be commended for the incredible efforts that many of the SEC staff have put into the development and enhancement of the quality of IAS. As a result of your efforts and the efforts of the FASB and many other conscientious and well intentioned professionals, you can be assured that IAS are now of sufficient quality to provide a core set of standards for non-US issuers that will meet the needs of US investors.

I appreciate the opportunity to comment on the Concepts Release, and will be happy to discuss these issues further if it is of any help in your deliberations.

Respectfully yours,

Trevor S. Harris
Jerome A. Chazen Professor of International Business, Columbia Business School

cc Sir Bryan Carsberg


Trevor S. Harris

Jerome A. Chazen Professor of International Business
Morgan Stanley Dean Witter Faculty Research Scholar
Columbia Business School
Columbia University, New York
Tel: (212) 854-3495 Fax: (201) 750-1485

Professor Harris earned his doctorate from the University of Washington in 1983 and has been at Columbia University since then. He became the Chair of the Accounting Department in 1999.

Professor Harris is a Chartered Accountant (SA) and was a local manager with Arthur Andersen before moving into academia. Since 1997, he has served as a consultant to Morgan Stanley Dean Witter on global accounting and valuation issues where he has headed up the Apples-to-Apples Global Equity Research project, and served as their accounting analyst. In June 2000, he is joining Morgan Stanley Dean Witter as a Managing Director in Equity Research. He has served as one of the United Nation's representatives on the Consultative Group of the International Accounting Standards Committee since 1990 and is a member of the International Capital Markets Advisory Committee at the New York Stock Exchange (NYSE). He assisted Daimler-Benz with their move to US-GAAP and their listing on the NYSE and has worked with several companies in evaluating their accounting relative to International Accounting Standards and US-GAAP. He has provided consulting services on international accounting, controllership and valuation issues to many large international corporations as well as Salomon Brothers and their clients, Standard & Poors and TIAA/CREF's investment group. He also served as the accounting and economics expert on a team hired to evaluate the pricing and rate-making structure of the US postal service.

Professor Harris has published widely in the academic accounting literature. His research has focused on the value-relevance of accounting information with an additional focus on international issues. Recent publications include: "Dividend Taxation in Firm Valuation: New Evidence" with D. Kemsley in Journal of Accounting Research (Autumn 1999); International Accounting Standards versus U.S.-GAAP: Empirical Evidence Based on Case Studies (Southwestern Publishing Company, 1995); "The Value Relevance of German Accounting Measures: An Empirical Analysis" with M. Lang and H.P. Möller in Journal of Accounting Research (Autumn 1994); and "A Comparison of the Value-Relevance of U.S. Versus Non-U.S.-GAAP Accounting Using Form 20-F Reconciliations" with E. Amir and E. Venuti Journal of Accounting Research (Supplement 1993);. Professor Harris has made presentations at over 100 conferences, institutes and universities around the world.


1 Easton, P.D., P.H. Eddey and T.S. Harris. "An Investigation of Revaluations of Tangible Long-Lived Assets." Journal of Accounting Research. (Supplement 1993) pp. 1-38.

2 Amir, E., T.S. Harris and E. Venuti. "A Comparison of the Value-Relevance of U.S. versus Non-U.S. GAAP Accounting Measures Using Form-20F Reconciliations." Journal of Accounting Research. (Supplement 1993) pp. 230-264. Rees, L. and P. Elgers. " The Market's Valuation of Non-Reported Accounting Measures: Retrospective Reconciliations of non-U.S. and U.S. GAAP." Journal of Accounting Research (Spring 1997) pp.115-127.

3 Harris, T.S. "International Accounting Standards versus US-GAAP: Evidence Based on Case Studies." Southwestern Publishing 1995.

4 Apples to Apples Global Airlines: Flight to Quality. Morgan Stanley Dean Witter, October 13 1998.