Initial Letter Date |
Form filed |
Market Capitalization |
11/21/2013 |
10-K |
$ 8,940 M |
Given your significant foreign operations, please enhance your liquidity disclosures to address the following: Disclose the amount of cash and short-term investments held by foreign subsidiaries as compared to your total amount of cash and short-term investments as of December 31, 2012; Disclose whether or not you would need to accrue and pay taxes if these amounts are repatriated; Disclose, if true, that you do not intend to repatriate these amounts; and Disclose the nature and extent of any legal or economic restrictions on the ability of your subsidiaries to transfer funds to you in the form of cash dividends, loans or advances and the impact such restrictions have had or are expected to have on your ability to meet cash obligations. Refer to Item 303(a)(1) of Regulation S-K, SEC Release 33-8350 Section IV and Financial Reporting Codification 501.06.a. |