Untitled Document

 

Initial Letter Date

Form filed

Market Capitalization

12/20/2013

10-K

$ 1,740 M

We note you have recorded a $[xx] million non-current deferred tax asset relating to acquired NOL carryforwards. We further note your disclosures that "a portion' of this amount is from your acquisition of [xx]. Please clarify for us how much of the deferred tax asset relates to [xx] and the nature of any other significant components of this balance. Further, please describe to us in greater detail the nature of the limitations on the use of these NOL carryforwards. Finally, explain to us how your determination of the realizability of the deferred tax assets considered these acquired NOL carryforwards. For example, we note that [xx] is domiciled in California, but you have a history of losses before income taxes in the United States.