Initial Letter Date |
Form filed |
Market Capitalization |
05/11/2012 |
10-K |
$ 3,630 M |
We note from your disclosures in Note 11 on page [xx] that you currently have unremitted foreign subsidiary earnings of $[xx] billion. Tell us your consideration of providing liquidity disclosures to discuss the potential tax impact associated with the repatriation of undistributed earnings of foreign subsidiaries. In this regard, consider disclosing the amount of cash and investments that are currently held by your foreign subsidiaries and disclose the tax impact of repatriating the undistributed earnings of foreign subsidiaries. We refer you to Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 33-8350. Please provide us with your revised disclosures in response to this comment. |