Initial Letter Date |
Form filed |
Market Capitalization |
01/26/2012 |
10-K |
$ 3,650 M |
We note on page [xx] that a substantial portion of your cash and investments is invested outside of the United States, and you retain a substantial portion of your cash in foreign jurisdictions for future reinvestment. Please advise us of the following: a. Tell us the total amount of cash and investments held in foreign jurisdictions as of January 29, 2011 and October 29, 2011 that would be subject to a significant tax effect upon their repatriation. b. Describe to us how you satisfy the cash needs of your domestic operations. c. Describe to us your specific plans for the reinvestment of undistributed earnings of foreign subsidiaries (ASC 740-30-25-17), and tell us the factors that management considered in determining that there is sufficient evidence that the undistributed earnings of your foreign subsidiaries will continue to be indefinitely reinvested (ASC 740-30-25- 19). Include your consideration of the amount and percentage of cash and investments held in foreign jurisdictions in your response. d. With a view towards discussion and analysis in future filings and to the extent material, provide disclosure to illustrate that some cash and investments are not potentially available to fund domestic operations without paying a significant amount of taxes upon their repatriation. Also provide us with the text of your proposed future disclosure in your response.impact your December 31, 2011 or future assertions regarding indefinite reinvestment. |