Initial Letter Date |
Form filed |
Market Capitalization |
04/10/2012 |
20-F |
$ 38,800 M |
On page [xx] you state that in 2011, you distributed dividends in the amount of $[xx] million out of your previously exempt income and paid the corporate tax due on such distributions. In future years, you expect to have sufficient income from non-exempt and strategic Approved Enterprise sources to fund your dividend distributions. You state in Note 1u to the financial statements on page F-14 that you have not provided deferred taxes on the income that you intend to permanently reinvest and not distribute as dividends. Please provide us proposed disclosure to be included in future periodic filings for Note 14 Income Taxes that complies with each of the disclosure requirements of ASC 740-30-50-2. Further, tell us your consideration of providing liquidity disclosures in MD&A to discuss that your use of certain funds may be limited. In this regard, please provide us proposed disclosure to be included in future periodic filings that includes a discussion of the amount of cash and investments that are currently held by your foreign subsidiaries that are not available to use by the Company or its other subsidiaries outside those foreign operations. Refer to Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 33-8350. |