Initial Letter Date |
Form filed |
Market Capitalization |
08/16/2012 |
10-K |
Private |
Given your recurring losses before income tax (expense) benefit, please discuss the nature of the U.S. deferred tax assets which have not been offset by a valuation allowance and how you determined that these would be realized. Please also address the following: Please expand your discussion of the nature of the positive and negative evidence that you considered, how that evidence was weighted, and how that evidence led you to determine it was not appropriate to record a valuation allowance on the remaining deferred income tax assets; Please disclose the amount of pre-tax income that you need to generate to realize the deferred tax assets; Please include an explanation of the anticipated future trends included in your projections of future taxable income; and Please disclose that the deferred tax liabilities you are relying on in your assessment of the realizability of your deferred tax assets will reverse in the same period and jurisdiction and are of the same character as the temporary differences giving rise to the deferred tax assets. Please show us in your supplemental response what the revisions in future filings will look like. |