Initial Letter Date |
Form filed |
Market Capitalization |
12/04/2013 |
10-K |
$ 413.08 M |
We note your disclosure on pages [xx] and [xx] regarding your reversal of approximately $[xx] million of valuation allowances against deferred tax assets of your French subsidiary due to the subsidiary no longer being in a cumulative loss position. We have the following comments: Please tell us the gross and net of valuation allowance amounts of the related deferred tax assets as of December 31, 2010, 2011 and 2012, as well as September 30, 2013, and describe their nature. Please explain in detail why you believed a valuation allowance was necessary in prior periods, as well as when it was initially recorded. Please explain in detail the facts and circumstances existing in 2012 that you considered in assessing the realizability of the deferred tax assets and ultimately reversing the $[xx] million valuation allowance. In your response, please specifically address each of the sources of income outlined in ASC 740-10-30-18, both positive and negative evidence, as well as your assessment of how objectively verifiable the evidence was and how that impacted your evaluation. Please describe in detail the specific facts and circumstances that changed from prior periods that caused your change in estimate. An example and comparison of current with preceding analyses of this deferred tax asset would assist our understanding. Please tell us whether there was any change in this valuation allowance during the nine months ended September 30, 2013, and if so, the specific facts and circumstances considered. If there was no change, please tell us the facts and circumstances supporting this conclusion as well. |