SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — Nov 20, 2018
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: Nov. 20, 2018 · CIK: 0000042582 · Accession: 0000000000-18-035792
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-01927
Referenced dates: December 22, 2016, February 3, 2017, January 9, 2017
Letter
November 20, 2018 Darren Wells Chief Financial Officer GOODYEAR TIRE & RUBBER CO /OH/ 200 Innovation Way Akron, Ohio 44316-0001 Re:GOODYEAR TIRE & RUBBER CO /OH/ Form 10-K for Fiscal Year Ended December 31, 2017 Filed February 8, 2018 File No. 001-01927 Dear Mr. Wells: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2017 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Policies Deferred Tax Asset Valuation Allowance and Uncertain Income Tax Positions, page 34 1.Considering the significance of the $749 million of foreign tax credits deferred tax assets to your consolidated financial statements and your conclusion that your undistributed foreign earnings are indefinitely reinvested, please expand your disclosures to clearly explain to investors the specific source of foreign income you are relying on to fully realize your foreign tax credits deferred tax assets. Please refer to comment 4 in our letter dated December 22, 2016, and comment 2 in our letter dated February 3, 2017, along with your corresponding letters dated January 9, 2017, and February 7, 2017, respectively.
FirstName LastNameDarren Wells Comapany NameGOODYEAR TIRE & RUBBER CO /OH/ November 20, 2018 Page 2 FirstName LastName Darren Wells GOODYEAR TIRE & RUBBER CO /OH/ November 20, 2018 Page 2 In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or Terence O'Brien, Accounting Branch Chief, at (202) 551-3355, with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing and Construction
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November 20, 2018
Darren Wells
Chief Financial Officer
GOODYEAR TIRE & RUBBER CO /OH/
200 Innovation Way
Akron, Ohio 44316-0001
Re:GOODYEAR TIRE & RUBBER CO /OH/
Form 10-K for Fiscal Year Ended December 31, 2017
Filed February 8, 2018
File No. 001-01927
Dear Mr. Wells:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2017
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies
Deferred Tax Asset Valuation Allowance and Uncertain Income Tax Positions, page 34
1.Considering the significance of the $749 million of foreign tax credits deferred tax assets
to your consolidated financial statements and your conclusion that your undistributed
foreign earnings are indefinitely reinvested, please expand your disclosures to clearly
explain to investors the specific source of foreign income you are relying on to fully
realize your foreign tax credits deferred tax assets. Please refer to comment 4 in our letter
dated December 22, 2016, and comment 2 in our letter dated February 3, 2017, along with
your corresponding letters dated January 9, 2017, and February 7, 2017, respectively.
FirstName LastNameDarren Wells
Comapany NameGOODYEAR TIRE & RUBBER CO /OH/
November 20, 2018 Page 2
FirstName LastName
Darren Wells
GOODYEAR TIRE & RUBBER CO /OH/
November 20, 2018
Page 2
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or Terence
O'Brien, Accounting Branch Chief, at (202) 551-3355, with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction