Initial Letter Date |
Form filed |
Market Capitalization |
03/30/2012 |
10-K |
$ 4,200 M |
We note from page [xx] that during 2011, $[xx] million of your deferred tax valuation allowance was released. Please tell us the nature of the circumstances that resulted in the release of the valuation allowance and the positive evidence which supported the basis for your conclusions. Your response should state the amounts released related to the foreign subsidiaries, restructuring and other items. We may have further comment upon receipt of your response. |