SecProbe.io

Mail Stop 4628
May 9, 201 7

Via E -mail
Robb L. Voyles
Interim  Chief Financial Officer
Halliburton Company
3000 North Sam Houston Parkway East
Houston, Texas 77032

Re: Halliburton Company
Form 10 -K for Fiscal Year Ended December 31, 201 6
Filed February 7, 201 7
File No. 1-03492

Dear Mr. Voyles :

We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respon d.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2016

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
19

Results of Operations in 2016 Compared to 2015, page 28

1. The response to prior year comment 2 in your letter dated June 6, 2016 regarding
disclosure in your Form  10-K for the fiscal year ended December 31, 2015 stated that you
would expand the discussion of increases or decreases in revenue and operating income to
distinguish between causal factors.  However, the analysis of your operating results does
not appear to quantify the effect of each factor identified as the cause of a material change
to the amounts presented as part of your financial statements.  Revise to provide

Robb L. Voyles
Halliburton Company
May 9, 201 7
Page 2

 disclosure consistent with your prior letter.  Refer to Item 303(a)(3) of Regulation S -K
and section III.B. of SEC Release No. 33 -8350.
Critical Accounting Estimates, page 34

Value of Long -Lived Assets, Including Intangible Assets and Goodwill, page 35

2. In 2016, you recorded impairment charges on long -lived assets totaling approximately
$2.6 billion due to projected declines in asset utilization.  Disclosure in your filing states
that the fair value of your long -lived assets was based on a discounted cash  flow analysis,
which required the use of significant unobservable inputs.   Revise to provide additional
detail describing the types of long -lived assets for which the carrying value was not
deemed to be recoverable.   Your revised disclosure should discuss  the degree of
uncertainty associated with the key assumptions used in determining the fair value of
your long -lived assets (i.e., revenue growth rates, expected profitability margins, discount
rates, etc)  and address potential events and/or changes in cir cumstances that could
reasonably be expected to negatively affect these key assumptions.  Refer to Item
303(a)(3)(ii) of Regulation S -K and Section V of SEC Release 33 -8350.
3. Tell us how your impairment tests on long -lived assets considered the political an d
economic turmoil in Venezuela  and your decision to begin curtailing activity there during
the first quarter of 2016.  For example, explain how these factors impacted the material
assumptions used in your impairment tests.  Include information in your res ponse
quantifying the dollar amounts of your long -lived assets in Venezuela.
Allowance for Bad Debts, page 37

4. We note the disclosure in your Form 10 -K regarding delays in the collection of payments
on your outstanding trade receivables in Venezuela which has led you to classify a
portion of these receivables within “Other assets.”  We also note risk factor disclosure
stating that you could be adversely affected by any delays in receiving payment on your
receivables from your primary customer in Venezuela o r their failure to pay a significant
amount of your outstanding receivables.  Revise to provide additional disclosure
describing the process through which you analyze the collectability of these receivables,
including your consideration of factors such as delays in collection, existing economic
conditions in Venezuela, and the curtailment of your operations there.  Include
appropriate context such as a reasonably detailed discussion of the original payment
terms and any changes made to the payment terms.  I n addition, provide us with an aging
of your accounts receivable as of March 31, 2017 related to your operations in Venezuela
that distinguishes between current and overdue accounts receivable and indicates the
extent of delinquency in reasonable increment s of time for overdue items.

Robb L. Voyles
Halliburton Company
May 9, 201 7
Page 3

 Notes to Consolidated Financial Statements

Note 10 – Income Taxes, page 60

5. We note that a deferred tax liability was recognized in 2016 for undistributed foreign
earnings as a portion of your cumulative undistributed foreign earnings outside of the
United States will no longer be permanently invested.  Tell us how the analysis of the
financial requirements of your United States companies and foreign subsidiaries and the
overall capital structure of your global organization led  you to determine that
undistributed earnings of certain foreign subsidiaries would no longer be permanently
reinvested outside the United States.  With your response, provide us with a discussion of
the specific plans you have for reinvestment of material  components of the undistributed
earnings of foreign subsidiaries you intend to permanently reinvest outside the United
States.  Refer to FASB ASC 740 -30-25-17.
6. You state that it is not practicable to estimate the additional amount of unrecognized
deferred  tax liability related to undistributed earnings of foreign subsidiaries permanently
reinvested outside the United States.  Explain your basis for this assertion, especially
considering the deferred tax liability recognized in 2016 for undistributed foreig n
earnings that will no lon ger be permanently reinvested. Refer to FASB ASC 740 -30-50-2.
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 Wei Lu, Staff Accountant, at (202)  551-3725 or me at (202) 551 -3311
with any other questions.

Sincerely,

 /s/ Ethan Horowitz

Ethan Horowitz
Branch  Chief
Office of Natural Resources