Initial Letter Date |
Form filed |
Market Capitalization |
09/06/2012 |
10-K |
$ 4,690 M |
We note from the disclosure in Note 8, Income Taxes, on page [xx] that you currently have foreign subsidiary earnings of approximately $[xx] million and these earnings are considered to be permanently invested in those businesses. Disclose how much of your cash, cash equivalents and short-term investments are held by your foreign subsidiaries. You should also disclose in your discussion of liquidity that you would need to accrue and pay taxes if these funds are repatriated. In addition discuss how your permanent reinvestment in foreign operations may affect your liquidity. Please refer to Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 33-8350 for additional guidance and please provide us with your proposed disclosures in response to this comment. |