Initial Letter Date |
Form filed |
Market Capitalization |
11/13/2013 |
10-Q |
$ 849.31 M |
We note from your disclosure on page [xx] that permanently invested funds held outside of the U.S. are available to fund operations in non-U.S. subsidiaries and this cash is also loaned to the U.S. parent company. We also note that under the Internal Revenue Code, these loans are permitted to be outstanding for 30 days or less and all such loans are required to be outstanding for a total of less than 60 days during the year. You disclose that amounts outstanding under this rule at September 30, 2013 were $[xx] million. With a view towards providing revised disclosure in future filings, please respond to the following: Describe to us in further detail your cash management and funding strategies that make cash held outside the U.S. available in the U.S. on a short-term basis without being subject to U.S. Tax. Tell us how long your loans have been outstanding. It appears that you had similar loans outstanding at March 31, June 30, and September 30, 2013. Tell us where the $[xx] million outstanding under the rule are included in your balance sheets at September 30, 2013. We note that cash and cash equivalents in your balance sheets totaled $[xx] million at September 30, 2013. Clarify whether the borrowings under the 5-year credit facility repaid during the interim period were at foreign or U.S. subsidiaries. |