Untitled Document

Initial Letter Date

Form filed

Market Capitalization

03/01/2012

6-K

$ 17,500 M

We note that you recorded income tax expense despite pretax loss "primarily due to [xx] continuing to not recognize the tax benefit associated with losses at [xx] and its national tax filing group in Japan which established a valuation allowance against certain deferred tax assets and equity in net loss of affiliated companies being reported  net of income taxes," with further reference to "profit from overseas and in the Financial Services segment" per your earnings call for the 3rd quarter of fiscal year 2012. Please  tell us what is meant by these disclosures. In addition, tell us in detail how the profit  from overseas and in the Financial Services segment resulted in your income tax expense.