Initial Letter Date |
Form filed |
Market Capitalization |
11/26/2013 |
20-F |
$ 571.19 M |
We note your disclosures on page [xx] that you have undistributed earnings related to your foreign subsidiaries, subject to taxes of their country of residence, which you intend to indefinitely reinvest. We also note disclosures at page [xx] that as of December 31, 2012 and 2011, most of your cash and cash equivalents were deposited with major Israeli, European, United States and Far Eastern banks. To the extent cash related to undistributed earnings could be considered material to an understanding of your liquidity and capital resources in future periods, such as for repayments of your outstanding debt, please revise your future filings to disclose the cash and investment amounts held by your foreign subsidiaries that would not be available for use in Israel without you incurring Israeli income taxes thereon. Please further provide a discussion of any known trends, demands or uncertainties as a result of this policy that are reasonably likely to have a material effect on the business as a whole or that may be relevant to your financial flexibility. Refer to Item 5(B)(1)(a)-(b) of Form 20-F and SEC Interpretive Release No. 34- 48960 (December 19, 2003). |