Untitled Document

Initial Letter Date

Form filed

Market Capitalization

12/11/2013

10-K

$ 25,120 M

We note your disclosure stating that approximately $[xx] billion was deemed to be indefinitely reinvested into the development and growth of your Canadian business as of December 31, 2012. Your disclosure also states that it is not practical to estimate the U.S. income taxes and foreign withholding taxes if such earnings were to be repatriated. Please provide us with a detailed explanation supporting this assertion considering that you disclosed your expectation to repatriate approximately $[xx] billion to the United States in the following quarter (i.e., as part of your Form 10-Q for the quarter ended March 31, 2013). Refer to FASB ASC 740-30-50-2.