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CORRESP
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CORRESP

3000 N. Sam Houston Parkway E. ● Houston, Texas 77032

Phone 281.871.2699

 June 2, 2017

Via EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

Washington, D.C. 20549

Attn:

Ethan Horowitz, Accounting Branch Chief

Office of Natural Resources

Re:

Halliburton Company

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

Filed February 7, 2017

File No. 1-03492

 Dear Mr. Horowitz:

Set forth below are the responses of Halliburton Company (“Halliburton” or “the Company”) to comments received from the
staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated May 9, 2017 with respect to Halliburton’s Form
10-K for the fiscal year ended December 31, 2016 filed with the Commission on February 7, 2017, File No. 1-03492 (the “Form 10-K”).

 For your convenience, each response is prefaced by the exact text of the Staff’s
corresponding comment in bold text.

 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 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.

Response: In the course of preparing our Form 10-K, we considered Item 303(a)(3) of Regulation S-K and related guidance, including but not limited to SEC Release No. 33-8350, as well as our response to prior year comment 2. After consideration of those items, we
believed that the disclosure in the Management’s Discussion and Analysis (MD&A) section of our Form 10-K complied with the requirements of Item 303(a) and related guidance. We respectfully submit that
Item 303(a) and related guidance require quantification of the causes of changes in revenue and operating income only to the extent necessary to an understanding of our business as a whole, and where identification and quantification of the extent
of contribution of each of two or more factors is necessary to an understanding of a material change. As we discussed in our response to the prior year comment letter, we provide quantification in cases in which we are able to distinguish between
causal factors related to changes in prices, volume or any new products and services, and where such causal factors are material and necessary to an understanding of our business as a whole.

The MD&A section of our Form 10-K describes the various factors that have a material impact on our
business, including oil and natural gas prices and other global economic factors, both of which are the primary drivers for increases or decreases in demand for our products and services. We provide quantitative information regarding oil and natural
gas pricing and a quantitative analysis of rig count, which provides a proxy for volume demand for our products and services. While we describe changes in our reported results with reference to greater or lesser activity in particular product
service lines (PSL) or geographic areas in which we operate, we do not believe that a quantification of the underlying changes in volume and pricing for a particular PSL or geographic area is material in all cases to investors’ understanding of
our results. This approach is consistent with how management understands and evaluates Company performance internally. In addition, we generally are not able to differentiate with precision between the impact of pricing and volume on increases or
decreases in revenues and operating income. In cases where quantification is not material or where we cannot differentiate between causal factors, we use the terms “primarily” or “partially offset by” to convey the causes of
changes from period to period. The absence of a quantification of individual named items covered by the terms “primarily” or “partially offset by” conveys the concept that no individual item need be quantified to assist the
reader in understanding a variance between the two periods.

 In future filings, we will continue to be mindful of the requirements of Item
303(a)(3) and related guidance, and will expand the discussion of and quantify the causes of increases or decreases in revenue and operating income where material to an investors’ understanding of our results and where we are able to
distinguish between causal factors.

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 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 circumstances 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.

Response: We acknowledge the Staff’s comment on providing additional detail describing the types of long-lived assets for which the
carrying value was not deemed to be recoverable. For the year ended December 31, 2016, we recorded approximately $2.6 billion of fixed asset impairments attributable to our Completion and Production (C&P) and Drilling and Evaluation
(D&E) operating segments, as follows:

 (in millions)

C&P

D&E

Total

 Machinery and equipment

$
1,585

$
863

$
2,449

 Buildings and property improvements

65

30

95

 Other

6

1

6

 Total

$
1,656

$
894

$
2,550

 Market conditions continued to weaken in the first quarter of 2016 with a significant decline in oil prices and
rig count, which prompted us to perform additional impairment assessments to test the recoverability of our long-lived assets in accordance with FASB ASC 360-10-35-21. Of the total $2.4 billion of machinery and equipment that we impaired during 2016, approximately $1.1 billion was attributable to our Production Enhancement PSL, the majority of
which was located in North America. As disclosed in Note 3 of our Form 10-K, deteriorated market conditions during 2016, particularly the severe contraction in the size of the overall North America hydraulic
fracturing market, resulted in excess equipment not being utilized in our operations. In addition, as previously disclosed in our Form 10-K, we have been converting our hydraulic fracturing fleet in North
America to a new Q10 pump and blender design. As a result of the reduced customer demand and technological changes, we impaired or wrote off a large portion of our older equipment. This disclosure combined with our PP&E disclosures contained in
Note 7 to the consolidated financial statements provide the reader with the types of assets that were written off during 2016.

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 We also acknowledge the Staff’s comment on discussing the degree of uncertainty associated
with the key assumptions used in determining the fair value of our long-lived assets and addressing potential events and/or changes in circumstances that could reasonably be expected to negatively affect these key assumptions. We have considered
Item 303(a)(3)(ii) of Regulation S-K and Section V of SEC Release 33-8350 in our financial statement disclosures and we respectfully submit that we believe our current
disclosures included in Risk Factors on trends in oil and gas prices, Critical Accounting Estimates, and Note 3 to the consolidated financial statements incorporate this information. However, in the Company’s Form
10-K filing for the fiscal year ended December 31, 2017, and any future filings which incorporate material long-lived asset impairments, we will include the quantitative information discussed above and
expand on our impairment disclosures as follows:

 We assessed the fair value of our long-lived assets based on a discounted cash flow
analysis, which required the use of estimates representing significant unobservable inputs such as management’s short-term and long-term forecast of operating performance, including revenue growth rates and expected profitability margins, and a
discount rate based on our weighted average cost of capital. As such, these analyses incorporate inherent uncertainties about commodity prices, supply and demand for our services, and future market conditions that are difficult to predict in
volatile economic environments. Should market conditions worsen or should a low commodity pricing environment persist for an extended period of time, our fair value assumptions of estimated future cash flows could be materially altered and we may be
required to record additional asset impairments. Such a potential impairment charge could have a material adverse impact on our operating results.

3.
Tell us how your impairment tests on long-lived assets considered the political and 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 response quantifying the dollar amounts of your long-lived assets in Venezuela.

Response: We perform our impairment tests on long-lived assets in accordance with FASB ASC 360-10-35, which states that a long-lived asset or assets shall be grouped with other assets and liabilities at the lowest level for which identifiable cash flows are largely independent of the cash flows of
other assets and liabilities to determine whether the carrying amount is recoverable. Estimates of future cash flows used to test the recoverability of long-lived assets include only the future cash flows that are directly associated with and that
are expected to arise as a direct result of the use of the asset group. These estimates of future cash flows are made for the remaining useful life and are based on the service potential of the asset group at the date of the impairment test.

We performed our impairment assessments at the PSL level, which represented the lowest level of identifiable cash flows in accordance with the
accounting standard. Since equipment in Venezuela may be redeployed for utilization in other geographic areas where we have identified a business need, we did not perform our impairment test at the Venezuela-country level. As a result of our overall
PSL impairment analysis, the impairment charge that we recorded included approximately $30 million for long-lived assets in Venezuela. While Venezuela has experienced considerable political and economic turmoil, which resulted in our decision
to begin curtailing activity in Venezuela

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during the first quarter of 2016, the macroeconomic environment in the country and the reduction of revenue as a direct result of such curtailment was not significant enough to trigger any
additional impairment charges. In conjunction with this curtailment, we did not deploy any new fixed assets into the country. It should be noted that our long-lived assets in Venezuela are not material to our overall business (approximately
$78 million of net property, plant and equipment at March 31, 2017).

 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 or 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. In 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 increments of time for overdue items.

 Response: We acknowledge the Staff’s
comment on providing additional disclosure regarding the process in which we analyze the collectability of our receivables in Venezuela, as well as providing further information on aging of receivables and original payment terms.

We have an extensive process to evaluate the collectability of outstanding receivables and analyze and monitor the financial solvency of all
customers on a routine basis to ensure they are able to meet their short-term customer obligations and that they are able to continue to generate operating cash flows. Among other things, we analyze our customer’s historical time to pay,
financial condition and various financial metrics, debt structure, credit agency ratings, production profile, political and economic factors in countries of operations, and other customer-specific factors.

We are submitting under separate cover as Exhibit A to this letter the aging of our accounts receivable as of March 31, 2017 and
other information related to our operations in Venezuela. This submission will be made together with a request that the submitted materials be kept confidential in accordance with Rule 83 of the SEC’s Rules of Practice, and that the submitted
materials be returned promptly following completion of the Staff’s review thereof in accordance with Rule 12b-4 under the Securities Exchange Act of 1934, as amended.

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 In future filings, including our next Quarterly Report on Form
10-Q, we will expand on the process through which we analyze the collectability of these receivables by disclosing:

We have an extensive process to evaluate the collectability of outstanding receivables and routinely monitor the financial stability of all
of our customers. Among other things, we analyze our customer’s historical time to pay, financial condition and various financial metrics, debt structure, credit agency ratings, production profile, political and economic factors in countries of
operations, and other customer-specific factors. Although we have continued to experience delays in collecting payments on our receivables from our primary customer in Venezuela, our outstanding receivables are not disputed, and we have not
historically had material write-offs relating to this customer. We continue to believe these receivables are collectable. We are actively managing our relationship with this customer with active dialogue between key executives of both companies.

 Notes to Consolidated Financial Statements

Note 10 – Income Taxes, page 60

5.
We note that