The Financial Accounting Standards Board (FASB) has now posted a Staff Q&A that specifically outlines what private and not-for-profit entities who wish to apply the SEC guidance on deferred taxes found in Staff Accounting Bulletin 118 should do.
The FASB has published a Staff Q&A, Whether Private Companies and Not-For-Profit Entities Can Apply SAB 118, that gives the full position of the staff. The document does require private and not-for-profit entities electing to apply SAB 118 to give all disclosures required in that bulletin, noting:
The FASB staff believes, however, that if a private company or a not-for-profit entity applies SAB 118, it should apply all relevant aspects of the SAB in its entirety. This would include the disclosures listed in SAB 118. The FASB staff also believes that a private company or a not-for-profit entity that applies SAB 118 should disclose its accounting policy of applying SAB 118 in accordance with paragraphs 235-10-50-1 through 50-3 of the Accounting Standards Codification.