Initial Letter Date |
Form filed |
Market Capitalization |
12/30/2013 |
10-Q |
$ 776.9 M |
You disclose that the completion of your long-term financing arrangement in the first quarter of 2013 resolved a significant negative factor that enabled you to release $[xx] million in valuation allowances against deferred income tax assets in fiscal 2013. Please tell us the significant negative factor that was resolved and explain why/how it was resolved by the new financing arrangement. Explain to us why and how the new financing arrangement impacted your evaluation of a valuation allowance and determination of income tax expense in general. In particular, tell us the factors existing prior to the new financing arrangement that were affected by or changed as a result of the new arrangement and why the new arrangement was able to affect them differently than the prior financing arrangements in place such that a valuation allowance was no longer necessary. |