Untitled Document

Initial Letter Date

Form filed

Market Capitalization

06/21/2012

10-Q

$ 2,780 M

We note that you recorded a discrete tax benefit of approximately $[xx] million from the write-off of the historical tax basis of an investment. Please tell us more about this tax benefit, the circumstances surrounding it and refer to any authoritative guidance you relied upon when determining your accounting. As part of your response, please tell us how you concluded that your current disclosures sufficiently explain the nature of this discrete tax benefit