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 FOURTE E NTH E D ITI O N

CO MPA R ATI V E
INTE RN ATI O N A L
ACCOUNTIN G
C HRI STO PHE R N O B ES
RO B E RT PA RK E R
Contents

Contributors xvi
Preface xvii

Part I SETTING THE SCENE

1 Introduction 3
Contents 3
Objectives 3
1.1 Differences in financial reporting 4
1.2 The global environment of accounting 6
1.3 The nature and growth of MNEs 15
1.4 Comparative and international aspects of accounting 18
1.5 Structure of this book 21
Summary 23
References 24
Useful websites 25
Questions 26

2 Causes and examples of international differences 27

Contents 27
Objectives 27
2.1 Introduction 28
2.2 Culture 29
2.3 Legal systems 31
2.4 Providers of finance 33
2.5 Taxation 38
2.6 Other external influences 41
2.7 The profession 43
2.8 Conclusion on the causes of international differences 43
2.9 Two examples of international differences 45
Summary 53
References 54
Questions 57

vii
Contents

3 International classification of financial reporting 59

Contents 59
Objectives 60
3.1 Introduction 60
3.2 The nature of classification 61
3.3 Classifications by social scientists 63
3.4 Classifications in accounting 64
3.5 Extrinsic classifications 68
3.6 Intrinsic classifications: 1970s and 1980s 72
3.7 Developments related to the Nobes classification 78
3.8 Further intrinsic classification 80
3.9 Is there an Anglo-Saxon group? 80
3.10 Classification in an IFRS world 82
3.11 A synthesis of accounting classifications 83
Summary 84
References 85
Questions 89

4 International harmonisation 90
Contents 90
Objectives 90
4.1 Introduction 91
4.2 Reasons for, obstacles to and measurement of harmonisation 92
4.3 The International Accounting Standards Committee 95
4.4 Other international bodies 104
4.5 The International Accounting Standards Board 108
4.6 International harmonisation of public sector reporting 113
Summary 114
References 115
Useful websites 118
Questions 118

Part II FINANCIAL REPORTING BY LISTED GROUPS

USING IFRS OR US GAAP

5 The background to financial reporting by listed groups 123

Contents 123
Objectives 123
5.1 Introduction 124
viii
 Contents

5.2 The legal and political context of international standards 125

5.3 Adoption of, and convergence with, IFRS 125
5.4 IFRS in the EU 130
5.5 IFRS/US differences 133
5.6 Convergence of IFRS and US GAAP 137
5.7 International financial analysis 139
Summary 148
References 149
Useful websites 154
Questions 154

6 IFRS in context: concepts, presentation

and revenue 155
Contents 155
Objectives 155
6.1 Introduction 156
6.2 The conceptual framework 159
6.3 IFRS requirements on presentation and accounting policies 164
6.4 Revenue and foreign currency transactions 168
6.5 Disclosures, and management commentary 171
Summary 172
References 172
Further reading 173
Useful websites 173
Questions 173

7 IFRS in context: assets and liabilities 175

Contents 175
Objectives 176
7.1 Introduction 176
7.2 Overview of accounting for tangible non-current assets 177
7.3 Lease accounting 178
7.4 Recognition of intangible assets 180
7.5 Measurement of non-current assets 181
7.6 Inventories 184
7.7 Financial instruments 185
7.8 Provisions 190
7.9 Employee benefits 195
7.10 Deferred tax 199
7.11 Synthesis on measurement of liabilities 205
Summary 206

ix
Contents

References 207
Questions 208

8 IFRS in context: group accounting 209

Contents 209
Objectives 209
8.1 Introduction 210
8.2 Rate of adoption of consolidation 211
8.3 International harmonisation from the 1970s onwards 213
8.4 Definitions of entities in which the group invests 214
8.5 Techniques of consolidation 219
8.6 Publication requirements and practices 225
Summary 226
References 227
Questions 228

9 Different versions of IFRS practice 229

Contents 229
Objectives 229
9.1 Introduction 230
9.2 Three aspects of the varied regulatory context of IFRS practice 230
9.3 Six types of scope for varied application of IFRS 233
9.4 Motivations for varied IFRS practice 238
9.5 Examples of varied IFRS practice 240
9.6 Changes in IFRS practice over time 243
9.7 Implications of the different versions of IFRS practice 244
Summary 245
References 245
Questions 247

10 Financial reporting in the United States 248

Contents 248
Objectives 249
10.1 Introduction 249
10.2 Regulatory framework 250
10.3 Accounting standard-setters 255
10.4 The conceptual framework 258
10.5 Contents of annual reports 261
10.6 Accounting principles 265
10.7 Consolidation 272

x
 Contents

10.8 Synthesis of differences from IFRS 274

Summary 276
References 276
Further reading 278
Useful websites 278
Questions 278

11 Political lobbying on accounting standards:

US, UK and international experience 279
Contents 279
Objectives 279
11.1 Introduction 280
11.2 Motivations for political lobbying 282
11.3 Political lobbying up to 1990 283
11.4 US political lobbying from 1990 293
11.5 Political lobbying of the IASC/IASB 298
11.6 Preparer attempts to control the accounting standard-setter 302
11.7 Political lobbying of the FASB’s convergence with the IASB 305
11.8 Some concluding remarks 307
Summary 308
References 308
Useful websites 311
Questions 312

Part III CHINA AND JAPAN

12 Financial reporting in China and Japan 315

Contents 315
Objectives 316
12.1 Introduction 316
12.2 Japan: regulatory issues 317
12.3 Japan: accounting practices 326
12.4 Japan: differences from IFRS 331
12.5 China: regulatory issues 333
12.6 China and IFRS 338
Summary 341
References 342
Useful websites 345
Questions 345
Appendix 12.1 ASBE Standards 346
xi
Contents

Part IV FINANCIAL REPORTING BY INDIVIDUAL COMPANIES

13 The context of financial reporting by

individual companies 351
Contents 351
Objectives 351
13.1 Introduction 351
13.2 Outline of differences between national rules and IFRS 352
13.3 The survival of national rules 354
13.4 Financial reporting, tax and dividend distribution 355
13.5 Special rules for private companies 356
13.6 Special rules for small companies 360
Summary 361
References 362
Useful websites 363
Questions 363

14 Harmonisation and transition in Europe 364

Contents 364
Objectives 364
14.1 Introduction 365
14.2 Harmonisation within the European Union 365
14.3 Transition in Central and Eastern Europe 374
Summary 383
References 383
Useful websites 386
Questions 387

15 Making accounting rules for unlisted business

enterprises in Europe 388
Contents 388
Objectives 388
15.1 Introduction 388
15.2 Who makes the accounting rules? 389
15.3 Which business enterprises are subject to accounting rules? 400
Summary 404
References 405
Further reading 407
Useful websites for Chapters 15 and 16 408

xii
 Contents

Questions 408
Appendix 15.1 Contents of the Plan Comptable Général
(relating to financial accounting and reporting) 410
Appendix 15.2 Financial accounting chart of accounts, Classes 1–7
in the Plan Comptable Général (ANC’s translation of
1999 chart, adjusted for changes in 2014) 411

16 Accounting rules and practices of individual

companies in Europe 413
Contents 413
Objectives 413
16.1 Introduction 413
16.2 France 414
16.3 Germany 420
16.4 United Kingdom 425
Summary 427
References 428
Further reading 429
Useful websites 429
Questions 429
Appendix 16.1 Formats for French financial statements
(2016 Plan Comptable) 430
Appendix 16.2 Formats for German financial statements 433
Appendix 16.3 Formats for British financial statements 436

Part V SPECIAL ISSUES IN REPORTING BY MNEs

17 Foreign currency translation 443

Contents 443
Objectives 444
17.1 Introduction 444
17.2 Translation of transactions 447
17.3 Introduction to the translation of financial statements 451
17.4 The US initiative in the 1970s 454
17.5 The temporal method versus the current rate method 457
17.6 Current US GAAP 461
17.7 Current IFRS 464
17.8 Translation of income and expenses 466
17.9 Accounting for translation gains and losses 468
17.10 Research findings 471
17.11 An alternative to exchange rates? 475

xiii
Contents

Summary 476
References 477
Further reading 478
Questions 478

18 Segment reporting 479

Contents 479
Objectives 479
18.1 What is segment reporting? 479
18.2 Segment reporting regulations 482
18.3 Constraints on the benefits of segment reporting 490
18.4 Assessing the benefits of segment reporting 493
Summary 501
References 501
Questions 505

Part VI MONITORING AND ENFORCEMENT

19 International auditing 509

Contents 509
Objectives 509
19.1 Introduction 510
19.2 Reasons for the internationalisation of auditing 512
19.3 Promulgating international standards 516
19.4 The international audit process 523
Summary 537
References 537
Further reading 538
Useful websites 538
Questions 539

20 Enforcement of financial reporting standards 540

Contents 540
Objectives 540
20.1 Introduction 540
20.2 Modes of enforcement 542
20.3 United States 545
20.4 Europe 546
20.5 West Pacific rim 552
xiv
 Contents

Summary 554
References 555
Useful websites 557
Questions 558

APPENDICES
A. Synoptic table of accounting differences in eight GAAPs, 2020 559
B. Glossary of abbreviations 562
C. Suggested outline answers to some of the end-of-chapter questions 568
Author index 585
Subject index 590

Supporting resources
Visit go.pearson.com/uk/he/resources to find valuable online resources

For instructors
● Complete Instructor’s Manual
● PowerPoint slides that can be downloaded and used for presentations

For more information please contact your local Pearson Education sales
representative or visit go.pearson.com/uk/he/resources

xv
 Contributors

Editor and main author

Christopher Nobes Professor of Accounting at Royal Holloway (University of London)
and at the University of Sydney. He has also taught in Italy, the Netherlands, New
Zealand, Norway, Scotland, Spain and the United States. He was the 2002 ‘Outstanding
International Accounting Educator’ of the American Accounting Association, and
he won the ‘Distinguished Academic Award’ of the British Accounting and Finance
Association in 2015. He was a member of the Accounting Standards Committee of the
United Kingdom and Ireland from 1986 to 1990, and a UK representative on the Board
of the International Accounting Standards Committee from 1993 to 2001. He was
vice-chairman of the accounting committee of the Fédération des Experts Comptables
Européens, 1993–2015.

Former co-editor and co-author

Robert Parker Formerly Professor of Accounting at the University of Exeter and pro-
fessorial fellow of the Institute of Chartered Accountants of Scotland. He also practised
or taught in Nigeria, Australia, France and Scotland and was editor or joint editor of
Accounting and Business Research from 1975 to 1993. He was the British Accounting
Association’s ‘Distinguished Academic of the Year’ in 1997, and the 2003 ‘Outstanding
International Accounting Educator’ of the American Accounting Association.

Authors of contributed chapters

Diana Hillier formerly Partner, PricewaterhouseCoopers LLP in the United Kingdom.
(Chapter 19)
Stephen A. Zeff Professor of Accounting at Rice University Houston, Texas, USA.
(Chapter 11)

xvi
Preface

Purpose
Comparative International Accounting is intended to be a comprehensive and coherent
text on international financial reporting. It is primarily designed for undergraduate
and postgraduate courses in comparative and international aspects of financial report-
ing. A proper understanding requires broad overviews (as in Part I), but these must be
supported by detailed information on real countries and companies (as in Parts II to IV)
and across-the-board comparisons of major topics (as in Parts V and VI).
This book was first published in 1981. Until this present edition (the fourteenth),
the book was jointly written by Christopher Nobes and Robert Parker. However, Bob
Parker died shortly after the thirteenth edition was published in 2016. This edition is
dedicated to his memory; see obituaries in the 2016 volumes of Accounting and Business
Research and Accounting History. Bob’s last publication was a review of the development
of the contents of this book (and therefore of the world of international accounting)
over its thirteen editions from 1981 onwards. Readers can consult this in Volume 21
(Issue 4) of Accounting History.
This edition is a complete updating of the thirteenth edition. For example, since that
edition, the International Accounting Standards Board (IASB) issued a revised Concep-
tual Framework in 2018; many Japanese companies have volunteered to adopt Interna-
tional Financial Reporting Standards (IFRS); major new standards on lease accounting
have been issued by the IASB and in the United States (thereby creating new interna-
tional differences); and much relevant academic literature has been published.
In addition to the extensive updating, I have also:
● added a discussion of international differences in public sector accounting (in
Chapter 4); and
● completely re-arranged the material on the content of IFRS (by reworking the mate-
rial previously in Chapters 6, 9 and 16 as the new topic-focused Chapters 6, 7 and 8).
A revised manual for teachers and lecturers is available from go.pearson.com/uk/he/
resources. It contains several numerical questions and a selection of multiple-choice
questions. Suggested answers are provided for all of these and for the questions in the
text. In addition, there is now an extensive set of PowerPoint slides.

Authors
In writing and editing this book over many editions, Bob Parker and I tried to gain
from the experience of those with local knowledge. This is reflected in the nature of
those thanked below for advice and in the note on contributors. For example, the
original chapter on North America was co-authored by a Briton who had been assistant
research director of the US Financial Accounting Standards Board; his knowledge of

xvii
Preface

US accounting was thus interpreted through and for non-US readers. The amended
version of the US chapter is by this book’s author, who has taught in several US uni-
versities. This seems the most likely way to highlight differences and to avoid missing
important points through overfamiliarity. The chapter on political lobbying is written
by Stephen Zeff, an American who is widely acknowledged as having the best overview
of historical and international accounting developments. The original chapter on cur-
rency translation was written by John Flower, who taught in UK universities but then
worked in Brussels for the EU Commission, and now lives in Germany. The chapter
on auditing has been written and revised by those directly involved in international
audit regulation and practice.
The two original main authors had, between them, been employed in nine coun-
tries. Christopher Nobes currently holds university posts in Australia and the UK.

Structure
Part I sets the scene for a study of comparative international financial reporting. Many
countries are considered simultaneously in the introductory chapter and when exam-
ining the causes of the major areas of difference (Chapter 2). It is then possible to try
to put accounting systems into groups (Chapter 3) and to take the obvious next step
by discussing the purposes and progress of international harmonisation of financial
reporting (Chapter 4).
All this material in Part I can act as preparation for the other parts of the book. Part I
can, however, be fully understood only by those who become well informed about the
contents of the rest of the book, and readers should go back later to Part I as a summary
of the whole.
Part II examines financial reporting by listed groups. In much of the world this
means, at least for consolidated statements, using the rules of either the International
Accounting Standards Board or the United States. There are three chapters on the main
requirements of IFRS, written in an internationally comparative way. Then, Chapter 9
examines whether different national versions of IFRS exist. After that, Chapter 10 com-
pares US GAAP with IFRS, and Chapter 11 examines political lobbying about account-
ing standards.
Part III of the book deals with financial reporting in the world’s second and third
largest economies (China and Japan). They share much in common, including having
Roman-based commercial legal systems and having requirements for the consolidated
statements of listed companies that are separate from those for other types of report-
ing. Neither country directly imposes IFRSs or US GAAP, although the influences of
those systems have been strong. It is therefore clearer to deal with these major coun-
tries (as we do in Chapter 12) separately from those countries using IFRS or US GAAP.
Part IV concentrates on the point raised above: that many countries have separate
national rules for unlisted companies or unconsolidated statements. Chapter 13 exam-
ines a number of issues relating to the context of reporting by individual companies,
for example the relationship between accounting and tax. It also looks at the IFRS for
SMEs. Chapters 14 to 16 concentrate on Europe, where the world’s next three largest
economies (after the US, China and Japan) are located. EU harmonisation is studied in
Chapter 14. Then, Chapters 15 and 16 look at the making of the rules for reporting by

xviii
 Preface

individual companies in France, Germany and the UK, and at the content and exercise
of those rules.
Part V (Chapters 17 and 18) examines, broadly and comparatively, two major
accounting topics for multinational companies: foreign currency translation and seg-
ment reporting. Part VI (Chapters 19 and 20) looks at two matters that come at the end
of the financial reporting process: external auditing and the enforcement of the rules.
At the end of the book, there are three appendices: a synoptic table of accounting
differences across eight GAAPs, a glossary of abbreviations relevant to international
accounting, and suggested outline answers to some end-of-chapter questions. Finally,
there are two indexes: by author and by subject.

Acknowledgements
In the various editions of this book, we have received great help and much useful
advice from many distinguished colleagues in addition to our contributors. We espe-
cially thank Sally Aisbitt (deceased); Ignace de Beelde of Ghent University; Dr Ataur
Rahman Belal, Aston Business School, Aston University; Véronique Blum of Univer-
stité Grenoble Alpes; Andrew Brown of Ernst & Young; Emmanuel Charrier of Paris
Dauphine; John Carchrae of the Ontario Securities Commission; Terry Cooke of the
University of Exeter; John Denman and Peter Martin of the Canadian Institute of
Chartered Accountants; Brigitte Eierle of Bamburg University; Sheila Ellwood of the
University of Bristol; Maria Frosig and Niels Brock of Copenhagen Business School,
Denmark; Simon Gao of Edinburgh Napier University; Michel Glautier of ESSEC, Paris;
Christopher Hossfeld of ESCP, Paris; Dr Jing Hui Liu, University of Adelaide, Australia;
Horst Kaminski, formerly of the Institut der Wirtschaftsprüfer; Jan Klaassen of the
Free University, Amsterdam; Christopher Koch of the University of Mannheim; and
Stéphanie Tulleau Kontowicz of the University of Bordeaux; Yannick Lemarchand
of the University of Nantes; Ken Lemke of the University of Alberta; Klaus Machar-
zina of the University of Hohenheim; Rania Uwaydah Mardini of Olayan School of
Business, American University of Beirut; Malcolm Miller and Richard Morris of the
University of New South Wales; Geoff Mitchell, formerly of Barclays Bank; Jules Muis
of the European Commission; Ng Eng Juan of Nanyang Technological University of
Singapore; Sue Newberry of the University of Sydney: Graham Peirson of Monash
University; Sophie Raimbault of Groupe ESC, Dijon; Jacques Richard of the University
of Paris Dauphine; Alan Richardson of York University, Toronto; Alan Roberts of ESC
Rennes School of Business; Paul Rutteman, formerly of EFRAG; Etsuo Sawa, formerly
of the Japanese Institute of Certified Public Accountants; Hein Schreuder, formerly of
the State University of Limburg; Marek Schroeder of the University of Birmingham;
Patricia Sucher, formerly of Royal Holloway, University of London; Christian Stadler
of the University of Lancaster; Lorena Tan, formerly of Price Waterhouse, Singapore;
Ann Tarca of the University of Western Australia; Stéphane Trébucq of the University of
Bordeaux; Peter van der Zanden, formerly of Moret Ernst & Young and the University
of Tilburg; Gerald Vergeer of Moret Ernst & Young; Ruud Vergoossen of Royal NIVRA
and the Free University of Amsterdam; Jason Xiao, Cardiff University; Dr Yap Kim Len,
HELP University College, Malaysia; and Eagle Zhang of the University of Sydney. We
are also grateful for the help of many secretaries over the years.

xix
Preface

For this fourteenth edition, Stephen Zeff provided much useful advice on large parts
of the draft. Despite the efforts of all these worthies, errors and obscurities will remain,
for which I am culpable.
Christopher Nobes
Royal Holloway
(University of London),
and University of Sydney

Publisher’s acknowledgements
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xxiv
Another random document with
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faintest reflection in the pages of this diary. Even the Mischianza—
that marvellous combination of ball, banquet, and tournament—is
dismissed in a few brief sentences. “Ye scenes of Vanity and Folly,”
says the home-staying Quaker wife, though still without any
rancorous disapprobation of the worldly pleasures in which she has
no share. To withstand steadfastly the allurements of life, yet pass no
censure upon those who yield to them, denotes a gentle breadth of
character, far removed from the complacent self-esteem of the “unco
guid.” When a young English officer, whom Elizabeth Drinker is
compelled to receive under her roof, gives an evening concert in his
rooms, and the quiet house rings for the first time with music and
loud voices, her only comment on the entertainment is that it was
“carried on with as much soberness and good order as the nature of
the thing admitted.” And when he invites a dozen friends to dine with
him, she merely records that “they made very little noise, and went
away timeously.” It is a good tonic to read any pages so free from
complaints and repining.
The diary bears witness to the sad distress of careless
merrymakers when the British army prepared to take the field, to the
departure of many prominent Tories with Admiral Howe’s fleet, and
to the wonderful speed and silence with which Sir Henry Clinton
withdrew his forces from Philadelphia. “Last night,” writes Elizabeth
on the 18th of June, 1778, “there were nine thousand of ye British
Troops left in Town, and eleven thousand in ye Jerseys. This
morning, when we arose, there was not one Red-Coat to be seen in
Town, and ye Encampment in ye Jerseys had vanished.”
With the return of Congress a new era of discomfort began for
the persecuted Friends, whose houses were always liable to be
searched, whose doors were battered down, and whose windows
were broken by the vivacious mob; while the repeated seizures of
household effects for unpaid war taxes soon left rigid members of
the society—bound at any cost to obey the dictates of their
uncompromising consciences—without a vestige of furniture in their
pillaged homes. “George Schlosser and a young man with him came
to inquire what stores we have,” is a characteristic entry in the
journal. “Looked into ye middle room and cellar. Behaved
complaisant. Their authority, the Populace.” And again: “We have
taxes at a great rate almost daily coming upon us. Yesterday was
seized a walnut Dining Table, five walnut Chairs, and a pair of large
End-Irons, as our part of a tax for sending two men out in the Militia.”
This experience is repeated over and over again, varied occasionally
by some livelier demonstrations on the part of the “populace,” which
had matters all its own way during those wild years of misrule. When
word came to Philadelphia that Lord Cornwallis had surrendered, the
mob promptly expressed its satisfaction by wrecking the houses of
Friends and Tory sympathizers. “We had seventy panes of glass
broken,” writes Elizabeth calmly, “ye sash lights and two panels of
the front Parlour broke in pieces; ye Door cracked and violently burst
open, when they threw stones into ye House for some time, but did
not enter. Some fared better, some worse. Some Houses, after
breaking ye door, they entered, and destroyed the Furniture. Many
women and children were frightened into fits, and ’tis a mercy no
lives were lost.”
When peace was restored and the federal government firmly
established, these disorders came to an end; a new security reigned
in place of the old placid content; and a new prosperity, more
buoyant but less solid than that of colonial days, gave to
Philadelphia, as to other towns, an air of gayety, and habits of
increased extravagance. We hear no more of the men who went with
clubs from shop to shop, “obliging ye people to lower their prices,”—
a proceeding so manifestly absurd that “Tommy Redman, the
Doctor’s apprentice, was put in prison for laughing as ye Regulators
passed by.” We hear no more of houses searched or furniture carted
away. Elizabeth Drinker’s diary begins to deal with other matters,
and we learn to our delight that this sedate Quakeress was
passionately fond of reading romances;—those alluring, long-
winded, sentimental, impossible romances, dear to our great-
grandmothers’ hearts. It is true she does not wholly approve of such
self-indulgence, and has ever ready some word of excuse for her
own weakness; but none the less “The Mysteries of Udolpho” and its
sister stories thrill her with delicious emotions of pity and alarm. “I
have read a foolish romance called ‘The Haunted Priory; or the
Fortunes of the House of Rayo,’” she writes on one occasion; “but I
have also finished knitting a pair of large cotton stockings, bound a
petticoat, and made a batch of gingerbread. This I mention to show
that I have not spent the whole day reading.” Again she confesses to
completing two thick volumes entitled “The Victim of Magical
Illusions; or the Mystery of the Revolution of P—— L——,” which
claimed to be a “magico-political tale, founded on historic fact.” “It
may seem strange,” she muses, “that I should begin the year,
reading romances. ’Tis a practice I by no means highly approve, yet I
trust I have not sinned, as I read a little of most things.”
She does indeed, for we find her after a time dipping into—of all
books in the world—Rabelais, and retiring hastily from the
experiment. “I expected something very sensible and clever,” she
says sadly, “but on looking over the volumes I was ashamed I had
sent for them.” Mary Wollstonecraft’s “Vindication of the Rights of
Women” pleases her infinitely better; though she is unwilling to go so
far as the impetuous Englishwoman, in whom reasonableness was
never a predominant trait. Unrestricted freedom, that curbless
wandering through doubtful paths which end in social pitfalls, offered
no allurement to the Quaker wife in whom self-restraint had become
second nature; but her own intelligence and her practical capacity for
affairs made her respect both the attainments and the prerogatives
of her sex. In fact, she appears to have had exceedingly clear and
definite opinions upon most matters which came within her ken, and
she expresses them in her diary without diffidence or hesitation. The
idol of the Revolutionary period was Tom Paine; and when we had
established our own republic, the enthusiasm we felt for republican
France predisposed us still to believe that Paine’s turbulent
eloquence embodied all wisdom, all justice, and all truth. In
Philadelphia the French craze assumed more dangerous and absurd
proportions than in any other city of the Union. Her once decorous
Quaker streets were ornamented with liberty-poles and flower-strewn
altars to freedom, around which men and women, girls and boys,
danced the carmagnole, and shrieked wild nonsense about tyrants
and the guillotine. The once quiet nights were made hideous with
echoes of “Ça ira” and the Marseillaise. Citizens, once sober and
sensible, wore the bonnet rouge, exchanged fraternal embraces,
recited mad odes at dinners, and played tricks fantastic enough to
plunge the whole hierarchy of heaven into tears,—or laughter. “If
angels have any fun in them,” says Horace Walpole, “how we must
divert them!” Naturally, amid this popular excitation, “The Rights of
Man” and “The Age of Reason” were the best-read books of the day,
and people talked about them with that fierce fervour which forbade
doubt or denial.
Now Elizabeth Drinker was never fervent. Hers was that critical
attitude which unconsciously, but inevitably, weighs, measures, and
preserves a finely adjusted mental balance. She read “The Age of
Reason,” and she read “The Rights of Man,” and then she read
Addison’s “Evidences of the Christian Religion,” by way of putting
her mind in order, and then she sat down and wrote:—
“Those who are capable of much wickedness are, if their minds
take a right turn, capable of much good; and we must allow that Tom
Paine has the knack of writing, or putting his thoughts and words into
method. Were he rightly inclined, he could, I doubt not, say ten times
as much in favour of the Christian religion as he has advanced
against it. And if Lewis ye 17th were set up as King of France, and a
sufficient party in his favour, and Paine highly bribed or flattered, he
would write more for a monarchical government than he has ever
written on the other side.”
Yet orthodoxy alone, unsupported by intellect, had scant charm
for this devout Quakeress. She wanted, as she expresses it,
thoughts and words put into method. Of a most orthodox and pious
little book, which enjoyed the approbation of her contemporaries, she
writes as follows: “Read a pamphlet entitled ‘Rewards and
Punishments; or Satan’s Kingdom Aristocratical,’ written by John
Cox, a Philadelphian, in verse. Not much to the credit of J. C. as a
poet, nor to the credit of Philadelphia; tho’ the young man may mean
well, and might perhaps have done better in prose.”
“Pilgrim’s Progress,” however, she confesses she has read three
times, and finds that, “tho’ little thought of by some,” she likes it
better and better with each fresh reading. Lavater she admires as a
deep and original thinker, while mistrusting that he has “too good a
conceit” of his own theories and abilities; and the “Morals” of
Confucius she pronounces “a sweet little piece,” and finer than most
things produced by a more enlightened age.
This is not a bad showing for those easy old days, when the
higher education of women had not yet dawned as a remote
possibility upon any mind; and when, in truth, the education of men
had fallen to a lower level than in earlier colonial times. Philadelphia
was sinking into a stagnant mediocrity, her college had been robbed
of its charter, and the scholarly ambitions (they were never more
than ambitions) of Franklin’s time were fading fast away. Even
Franklin, while writing admirable prose, had failed to discover any
difference between good and bad verse. His own verse is as
cheerfully and comprehensively bad as any to be found, and he
always maintained that men should practise the art of poetry, only
that they might improve their prose. This purely utilitarian view of the
poet’s office was not conducive to high thinking or fine criticism; and
Elizabeth Drinker was doubtless in a very small minority when she
objected to “Satan’s Kingdom Aristocratical,” on the score of its
halting measures.
The most striking characteristic of our Quaker diarist is precisely
this clear, cold, unbiased judgment, this sanity of a well-ordered
mind. What she lacks, what the journal lacks from beginning to end,
is some touch of human and ill-repressed emotion, some word of
pleasant folly, some weakness left undisguised and unrepented. The
attitude maintained throughout is too judicial, the repose of heart and
soul too absolute to be endearing. Here is a significant entry,
illustrating as well as any other this nicely balanced nature, which
gave to all just what was due, and nothing more:—
“There has been a disorder lately among ye cats. Our poor old
Puss, who has been for some time past unwell, died this morning, in
ye 13th year of her age. Peter dug a grave two feet deep on ye bank
in our garden, under ye stable window, where E. S., Peter and I saw
her decently interred. I had as good a regard for her as was
necessary.”
Was ever affection meted out like this? Was there ever such
Quaker-like precision of esteem? For thirteen years that cat had
been Elizabeth Drinker’s companion, and she had acquired for her
just as good a regard as was necessary, and no more. It was not
thus Sir Walter spoke, when Hinse of Hinsdale lay dead beneath the
windows of Abbotsford, slain by the great staghound, Nimrod. It was
not thus that M. Gautier lamented the consumptive Pierrot. It is not
thus that the heart mourns, when a little figure, friendly and familiar,
sits no longer by our desolate hearth.
 FRENCH LOVE-SONGS

Quand on est coquette, il faut être sage;

L’oiseau de passage
Qui vole à plein cœur
Ne dort pas en l’air comme une hirondelle,
Et peut, d’un coup d’aile,
Briser une fleur.
—Alfred de Musset.

The literature of a nation is rooted in national characteristics. Foreign

influences may dominate it for a time; but that which is born of the
soil is imperishable, and must, by virtue of tenacity, conquer in the
end. England, after the Restoration, tried very hard to be French,
and the “happy and unreflecting wantonness” of her earlier song was
chilled into sobriety by the measured cadences of Gallic verse; yet
the painful and perverse effort to adjust herself to strange conditions
left her more triumphantly English than before. We are tethered to
our kind, and the wisest of all wise limitations is that which holds us
well within the sphere of natural and harmonious development.
It is true, however, that nationality betrays itself less in lyrics,
and, above all, less in love lyrics, than in any other form of literature.
Love is a malady, the common symptoms of which are the same in
all patients; and though love-songs—like battle-songs and drinking-
songs—are seldom legitimate offsprings of experience, they are
efforts to express in words that sweet and transient pain. “Les âmes
bien nées”—without regard to birthplace—clearly of their passion,
and seek their “petit coin de bonheur” under Southern and Northern
skies. The Latin races have, indeed, depths of reserve underlying
their apparent frankness, and the Saxons have a genius for self-
revelation underlying their apparent reticence; but these traits count
for little in the refined duplicity of the love-song.
Garde bien ta belle folie!
has been its burden ever since it was first chanted by minstrel lips.
M. Brunetière frankly admits the inferiority of the French lyric, an
inferiority which he attributes to the predominance of social
characteristics in the literature, as in the life of France. When poetry
is compelled to fulfil a social function, to express social conditions
and social truths, to emphasize fundamental principles and balance
contrasted forces, the founts of lyrical inspiration are early dried.
Individualism is their source,—the sharp, clear striking of the
personal note; and the English, says M. Brunetière, excel in this
regard. “To Lucasta. Going to the Warres,” has no perfect
counterpart in the love-songs of other lands.
Even the eager desire of the Frenchman to be always intelligible
(“That which is not lucid is not French”) militates against the
perfection of the lyric. So too does his exquisite and inborn sense of
proportion. “Measure,” says Mr. Brownell, “is a French passion;” but
it is a passion that refuses to lend itself to rapturous sentiment.
Et veut que l’on soit sage avec sobriété
is hardly a maxim to which the genius of the love-song gives willing
ear. Rather is she the La Belle Dame sans Merci, or the Elfin Lady
who rode through the forests of ancient France.

My sire is the nightingale,

That sings, making his wail,
In the wild wood, clear;
The mermaid is mother to me,
That sings in the salt sea,
In the ocean mere.

“What,” asks Mr. Brownell hopelessly, “has become of this Celtic

strain in the French nature?”—a strain which found vent in the
“poésie courtoise,” playful, amorous, laden with delicate subtleties
and fond conceits. This poesie—once the delight of Christendom—
echoes still in Petrarch’s sonnets and in Shakespeare’s madrigals;
but it is difficult to link its sweet extravagances with the chiselled
verse of later days, and critics forget the past in their careful
contemplation of the present. “French poetry,” says Mr. Zangwill,
“has always leant to the frigid, the academic, the rhetorical,—in a
word, to the prosaic. The spirit of Boileau has ruled it from his cold
marble urn.”
But long before Boileau lay in his urn—or in his cradle—the
poets of France, like the poets of Albion, sang with facile grace of
love, and dalliance, and the glory of youth and spring. The fact that
Boileau ignored and despised their song, and taught his obedient
followers to ignore and despise it also, cannot silence those early
notes. When he descended frigidly to his grave, Euterpe tucked up
her loosened hair, and sandalled her bare white feet, and girdled her
disordered robes into decent folds. Perhaps it was high time for
these reforms. Nothing is less seductive in middle age than the
careless gayety of youth. But once France was young, and Euterpe
a slip of a girl, and no grim shadow of that classic urn rested on the
golden days when Aucassin—model of defiant and conquering
lovers—followed Nicolette into the deep, mysterious woods.

Jeunesse sur moy a puissance,

Mais Vieillesse fait son effort
De m’avoir en sa gouvernance,

sang Charles d’Orléans, embodying in three lines the whole history

of man and song. Youth was lusty and folly riotous when Ronsard’s
mistress woke in the morning, and found Apollo waiting patiently to
fill his quiver with arrows from her eyes; or when Jacques Tahureau
watched the stars of heaven grow dim before his lady’s brightness;
or when Vauquelin de la Fresnaye saw Philis sleeping on a bed of
lilies, regardless of discomfort, and surrounded by infant Loves.
 J’admirois toutes ces beautez
Égalles à mes loyautez,
Quand l’esprit me dist en l’oreille:
Fol, que fais-tu? Le temps perdu
Souvent est chèrement vendu;
S’on le recouvre, c’est merveille.

Alors, je m’abbaissai tout bas,

Sans bruit je marchai pas à pas,
Et baisai ses lèvres pourprines:
Savourant un tel bien, je dis
Que tel est dans le Paradis
Le plaisir des âmes divines.

With just such sweet absurdities, such pardonable insincerities,

the poets of Elizabeth’s England fill their amorous verse. George
Gascoigne “swims in heaven” if his mistress smiles upon him; John
Lyly unhesitatingly asserts that Daphne’s voice “tunes all the
spheres;” and Lodge exhausts the resources of the vegetable and
mineral kingdoms in searching for comparisons by which to set forth
the beauties of Rosalind. The philosophy of love is alike on both
sides of the Channel, and expressed in much the same terms of soft
insistence. Carpe diem is, and has always been, the lover’s maxim;
and the irresistible eloquence of the lyric resolves itself finally into
these two words of warning, whether urged by Celt or Saxon. Herrick
is well aware of their supreme significance when he sings:—

Gather ye rose-buds while ye may,

Old Time is still a-flying:
And this same flower that smiles to-day,
To-morrow will be dying.
 Then be not coy, but use your time,
And while ye may, go marry;
For having lost but once your prime,
You may forever tarry.

Ronsard, pleading with his mistress, strikes the same relentless

note:—

Donc, si vous me croyez, Mignonne,

Tandis que vostre âge fleuronne
En sa plus vert nouveauté,
Cueillez, cueillez vostre jeunesse;
Comme à cette fleur, la vieillesse
Fera ternir vostre beauté.

May-day comes alike in England and in France. Herrick and

Jean Passerat, poets of Devonshire and of Champagne, are equally
determined that two fair sluggards, who love their pillows better than
the dewy grass, shall rise from bed, and share with them the
sparkling rapture of the early dawn. Herrick’s verse, laden with the
freshness of the Spring, rings imperatively in Corinna’s sleepy
ears:—

Get up, get up, for shame! The blooming Morn

Upon her wings presents the god unshorn.
See how Aurora throws her fair
Fresh-quilted colours through the air.
Get up, sweet Slug-a-bed, and see
The dew bespangling herb and tree.

And then—across the gayety of the song—the deepening note of

persuasion strikes a familiar chord:—
 Come, let us go, while we are in our prime;
And take the harmless folly of the time!
We shall grow old apace, and die
Before we know our liberty.

Passerat is no less insistent. The suitors of the sixteenth and

seventeenth centuries seem to have dedicated the chill hours of
early morning to their courtship. Nor was the custom purely pastoral
and poetic. When Lovelace makes his appointments with Clarissa
Harlowe at five A. M., the modern reader—if Richardson has a
modern reader—is wont to think the hour an unpropitious one; but to
Herrick and to the Pléiade it would have seemed rational enough.

Laissons le lit et le sommeil

Ceste journée:
Pour nous, l’Aurore au front vermeil
Est desjà née

sings the French poet beneath his lady’s window; adding, to

overcome her coyness—or her sleepiness—the old dominant
argument:—

Ce vieillard, contraire aus amans,

Des aisles porte,
Et en fuyant, nos meilleurs ans
Bien loing emporte.
Quand ridée un jour tu seras,
Mélancholique, tu diras:
J’estoy peu sage,
Qui n’usoy point de la beauté
Que si tost le temps a osté
De mon visage.
 No less striking is the similarity between the reproachful couplets
in which the singers of England and of France delight in denouncing
their unfaithful fair ones, or in confessing with harmonious sighs the
transient nature of their own emotions. Inconstancy is the breath of
love’s nostrils, and the inspiration of love’s songs, which enchant us
because they express an exquisite sentiment in its brief moment of
ascendency. The tell-tale past, the dubious future, are alike
discreetly ignored. Love in the drama and in the romance plays
rather a heavy part. It is too obtrusively omniscient. It is far too self-
assertive. Yet the average taxpayer, as has been well remarked, is
no more capable of a grand passion than of a grand opera. The
utmost he can achieve is some fair, fleeting hour, and with the
imperative gladness of such an hour the love-song thrills
sympathetically. It is not its business to

recapture
That first fine careless rapture.

It does not essay the impossible.

Now the old and nameless French poet who wrote—

Femme, plaisir de demye heure,

Et ennuy qui sans fins demeure,

was perhaps too ungraciously candid. Such things, when said at all,
should be said prettily.

Sigh no more, ladies, sigh no more,—

Men were deceivers ever;
One foot in sea, and one on shore,
To one thing constant never.
 Gay voices came bubbling with laughter from the happy days
that are dead. Sir John Suckling, whose admirable advice to an
overfaithful young suitor has been the most invigorating of tonics to
suitors ever since, vaunts with pardonable pride his own singleness
of heart:—

Out upon it! I have loved

Three whole days together,
And am like to love three more,
If it prove fair weather.

Time shall moult away his wings

Ere he shall discover
In the whole wide world again
Such a constant lover.

Sir John Sedley epitomizes the situation in his praises of that

jade, Phillis, whose smiles win easy pardon for her perfidy:—

She deceiving,
I believing,—
What need lovers wish for more?

And Lovelace, reversing the medal, pleads musically—and not in

vain—for the same gracious indulgence:—

Why shouldst thou sweare I am forsworn,

Since thine I vowed to be?
Lady it is already Morn,
And ’twas last night I swore to thee
That fond impossibility.
 Mr. Lang is of the opinion that no Gallic verse has equalled in
audacity this confession of limitations, this “Apologia pro Vita Sua;”
and perhaps its light-heartedness is well out of general reach. But
the French lover, like the English, was made of threats and promises
alike fruitless of fulfilment, and Phillis had many a fair foreign sister,
no whit more worthy of regard. Only, amid the laughter and raillery of
a Latin people, there rings ever an undertone of regret,—not
passionate and heart-breaking, as in Drayton’s bitter cry,—
Since there’s no help, come let us kiss and part,
but vague and subtle, linking itself tenderly to some long-ignored and
half-forgotten sentiment, buried deep in the reader’s heart.
Mais où sont les neiges d’antan?
A little sob breaks the smooth sweetness of Belleau’s verse, and
Ronsard’s beautiful lines to his careless young mistress are heavy
with the burden of sighs:—

Quand vous serez bien vieille, au soir, à la chandelle,

Assise auprès du feu, devisant et filant,
Direz, chantant mes vers, en vous esmerveillant:
‘Ronsard me célébroit du temps que j’estois belle.’

The note deepens as we pass into the more conscious art of

later years, but it is always French in its grace and moderation. How
endurable is the regret with which de Musset sings of Juana, who
loved him for a whole year; how musical his farewell to Suzon,
whose briefer passion lasted eight summer days:—

Que notre amour, si tu m’oublies,

Suzon, dure encore un moment;
Comme un bouquet de fleurs pâlies;
Cache-le dans ton sein charmant!
Adieu! le bonheur reste au gîte:
Le souvenir part avec moi:
 Je l’emporterai, ma petite,
Bien loin, bien vite,
Toujours à toi.

In Murger’s familiar verses, so pretty and gay and heartsick, in

the finer art of Gautier, in the cloudy lyrics of Verlaine, we catch
again and again this murmur of poignant but subdued regret, this
sigh for the light love that has so swiftly fled. The delicacy of the
sentiment is unmatched in English song. The Saxon can be
profoundly sad, and he can—or at least he could—be ringingly and
recklessly gay; but the mood which is neither sad nor gay, which is
fed by refined emotions, and tranquillized by time’s subduing touch,
has been expressed oftener and better in France. Four hundred and
fifty years ago François Villon touched this exquisite chord in his
“Ballade des Dames du Temps Jadis,” and it has vibrated gently ever
since. We hear it echoing with melancholy grace in these simple
lines of Gérard de Nerval:—

Où sont les amoureuses?

Elles sont au tombeau!
Elles sont plus heureuses,
Dans un séjour plus beau.

Nerval, like Villon, had drunk deep of the bitterness of life, but he
never permitted its dregs to pollute the clearness of his song:—
Et vent que l’on soit triste avec sobriété.
In the opinion of many critics, the lyric was not silenced, only
chilled, by the development of the classical spirit in France, and the
corresponding conversion of England. Its flute notes were heard now
and then amid the decorous couplets that delighted well-bred ears.
Waller undertook the reformation of English verse, and accomplished
it to his own and his readers’ radiant satisfaction; yet Waller’s seven-
year suit of Lady Dorothy Sidney is the perfection of that poetic love-
making which does not lead, and is not expected to lead, to anything
definite and tangible. Never were more charming tributes laid at the
feet of indifferent beauty; never was indifference received with less
concern. Sacharissa listened and smiled. The world—the august
little world of rank and distinction—listened and smiled with her,
knowing the poems were written as much for its edification as for
hers; and Waller, well pleased with the audience, nursed his passion
tenderly until it flowered into another delicate blossom of verse. The
situation was full of enjoyment while it lasted; and when the seven
years were over, Lady Dorothy married Henry, Lord Spencer, who
never wrote any poetry at all; while her lover said his last good-bye
in the most sparkling and heart-whole letter ever penned by
inconstant man. What would the author of “The Girdle,” and “Go,
Lovely Rose,” have thought of Browning’s uneasy rapture?

O lyric love, half angel and half bird,

And all a wonder and a wild desire.

He would probably have pointed out the exaggeration of the

sentiment, and the corresponding looseness of the lines. He would
certainly have agreed with the verdict of M. Sévelinges, had that
acute critic uttered it in his day. “It is well,” says M. Sévelinges, “that
passionate love is rare. Its principal effect is to detach men from all
their surroundings, to isolate them, to render them independent of
the relations which they have not formed for themselves; and a
civilized society composed of lovers would return infallibly to misery
and barbarism.”
Here is the French point of view, expressed with that lucidity
which the nation so highly esteems. Who shall gainsay its
correctness? But the Saxon, like the Teuton, is sentimental to his
heart’s core, and finds some illusions better worth cherishing than
truth. It was an Englishman, and one to whom the epithet “cynical”
has been applied oftenest, and with least accuracy, who wrote,—

When he was young as you are young,

When he was young, and lutes were strung,
And love-lamps in the casement hung.
 THE SPINSTER
The most ordinarie cause of a single life is liberty, especially
in certain self-pleasing and humorous minds, which are so
sensible of every restriction, as they wil goe neere to thinke their
girdles and garters to be bonds and shakles.—Bacon.

In the Zend-Avesta, as translated by Anquetil-Duperron, there is a

discouraging sentence passed upon voluntary spinsterhood: “The
damsel who, having reached the age of eighteen, shall refuse to
marry, must remain in Hell until the earth is shattered.”
This assurance is interesting, less because of its provision for
the spinster’s future than because it takes into consideration the
possibility of her refusing to marry;—a possibility which slipped out of
men’s minds from the time of Zoroaster until our present day. A vast
deal has been written about marriage in the interval; but it all bears
the imprint of the masculine intellect, reasoning from the masculine
point of view, for the benefit of masculinity, and ignoring in the most
natural manner the woman’s side of life. The trend of argument is
mainly in one direction. While a few cynics gibe at love and conjugal
felicity, the mass of poets and philosophers unite in extolling
wedlock. Some praise its pleasures, others its duties, and others
again merely point out with Euripides that, as children cannot be
bought with gold or silver, there is no way of acquiring these coveted
possessions save by the help of women. Now and then a rare word
of sympathy is flung to the wife, as in those touching lines of
Sophocles upon the young girls sold in their “gleeful maidenhood” to
sad or shameful marriage-beds. But the important thing to be
achieved is the welfare and happiness of men. The welfare and
happiness of women are supposed—not without reason—to follow
as a necessary sequence; but this is a point which excites no very
deep concern.
 Catholic Christendom throughout the Middle Ages, and long
afterwards, offered one practical solution to the problem of unmated
and unprotected womanhood,—the convent. The girl robbed of all
hope of marriage by bitter stress of war or poverty, the girl who
feared too deeply the turmoil and violence of the world, found shelter
in the convent. Within its walls she was reasonably safe, and her
vows lent dignity to her maidenhood. Bride of the Church, she did
not rank as a spinster, and her position had the advantage of being
accurately defined; she was part of a recognized social and
ecclesiastical system. No one feels this more solidly than does a nun
to-day, and no one looks with more contempt upon unmarried
women in the world. In her eyes there are but two vocations,—
wifehood and consecrated virginity. She perceives that the wife and
the religious are transmitters of the world’s traditions; while the
spinster is an anomaly, with no inherited background to give repute
and distinction to her rôle.
This point of view is the basis of much criticism, and has afforded
scope for the ridicule of the satirist, and for the outpourings of the
sentimentalist. A great many brutal jests have been flung at the old
maid, and floods of sickly sentiment have been wasted on her
behalf. She has been laughed at frankly as one rejected by men, and
she has been wept over as a wasted force, withering patiently under
the blight of this rejection. “Envy, hatred, malice, and all
uncharitableness” have been ascribed to her on one side, and a host
of low-spirited and treacly virtues, on the other. The spinster of
comedy is a familiar figure. A perfectly simple and ingenuous
example is the maiden aunt in “Pickwick,” Miss Rachel Wardle,
whom Mr. Tupman loves, and with whom Mr. Jingle elopes. She is
spiteful and foolish, envious of youth and easy to dupe. She is utterly
ridiculous, and a fair mark for laughter. She is pinched, and withered,
and hopelessly removed from all charm of womanhood; and—it may
be mentioned parenthetically—she is fifty years old. We have her
brother’s word for it.
There is nothing in this straightforward caricature that could, or
that should, wound anybody’s sensibilities. The fun is of a robust
order; the ridicule has no subtlety and no sting. But the old maid of