SEC Comment Letter for INTEL CORP (INTC) (CIK 0000050863) (INTC) — Apr 17, 2017
INTEL CORP (INTC) (CIK 0000050863)
Date: April 17, 2017 · CIK: 0000050863 · Accession: 0000000000-17-013129
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-06217
Letter
Mail Stop 3030 April 1 7, 2017 Via E -mail Robert H. Swan Executive Vice President and Chief Financial Officer Intel Corp oration 2200 Mission College Boulevard Santa Clara, California 95054 -1549
Re: Intel Corp oration Form 10-K for the Fiscal Year Ended December 31, 2016 Filed February 17, 2017 File No. 000-06217
Dear Mr. Swan :
We have reviewed your filing an d 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 respond. If you do not be lieve 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 the Fiscal Year Ended December 31, 2016
Item 7. Management’s Discussion and Analysis . . ., page 28
Data Center Group, page 35
1. Please revise future filings to clarify the relative amounts of growth attributable to the markets you identify, whether any markets served by this segment materially offse t such growth and the reasons underlying those changes. For example, please revise future filings to disclose the relative amounts of growth related to “cloud service provider and communication service provider market segment” and the offsetting impact c aused by other markets served by this segment, and the reasons those markets changed. We no te, in this regard, management ’s statements during its 4th quarter earnings call regarding the percentage growth in cloud and communication, the decline in enterpri se and government
Robert H. Swan Intel Corporation April 1 7, 2017 Page 2
and reasons for the growth in cloud and decline in enterprise. Please also refer to your response to comment 2 in your letter to us dated April 23, 2013.
Internet of Things Group, page 37
2. Please revise future filings to provide a clea r and quantifi ed discussion of the underlying material causes of changes in the results you disclose. We note that your current disclosure refers to general causes such as “higher IOTG platform unit sales” and “higher IOTG platform average selling prices,” but does not explain the reasons for these changes or quantify how each factor contributed to the period over period increases. Additionally, if, as indicated in management’s 4th quarter earnings call, the changes to which you refer were driven primarily by specific markets served by this group, please revise to clarify the markets driving those changes and any material offsetting impact in other markets.
Provision for Income Taxes, page 41
3. We note the discussion of the decrease in your effective tax rate due to a higher proportion of income generated in lower tax jurisdictions each period. We also note the growing impact of non -U.S. income taxed at different rates on your effective tax rate disclosed in Note 8 to your financial statements. In future f ilings please revise this section to explain the impact of non -U.S. lower taxed jurisdictions on your effective tax rate, including a discussion of the primary taxing jurisdictions where your foreign earnings are derived, the location of tax holidays and t he relevant statutory rates in those jurisdictions. Discuss any uncertainties relating to the income tax rates or benefits you currently receive in those jurisdictions. Refer to Item 303(a)(3) of Regulation S -K.
We remind you that the company and its man agement 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 Kristin Lochhead at (202) 551 -3664 or Brian Cascio, Accounting Branch Chief, at (202) 551 -3676 if you have questions regarding comments on the financial statements and re lated matters. Please contact Geoff Kruczek , Special Counsel, at (202) 551 - 3641 or me at (202) 551 -3528 with any other questions.
Sincerely,
/s/ Amanda Ravitz
Show Raw Text
Mail Stop 3030
April 1 7, 2017
Via E -mail
Robert H. Swan
Executive Vice President and Chief Financial Officer
Intel Corp oration
2200 Mission College Boulevard
Santa Clara, California 95054 -1549
Re: Intel Corp oration
Form 10-K for the Fiscal Year Ended December 31, 2016
Filed February 17, 2017
File No. 000-06217
Dear Mr. Swan :
We have reviewed your filing an d 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 respond. If you do not be lieve 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 the Fiscal Year Ended December 31, 2016
Item 7. Management’s Discussion and Analysis . . ., page 28
Data Center Group, page 35
1. Please revise future filings to clarify the relative amounts of growth attributable to the
markets you identify, whether any markets served by this segment materially offse t such
growth and the reasons underlying those changes. For example, please revise future
filings to disclose the relative amounts of growth related to “cloud service provider and
communication service provider market segment” and the offsetting impact c aused by
other markets served by this segment, and the reasons those markets changed. We no te,
in this regard, management ’s statements during its 4th quarter earnings call regarding the
percentage growth in cloud and communication, the decline in enterpri se and government
Robert H. Swan
Intel Corporation
April 1 7, 2017
Page 2
and reasons for the growth in cloud and decline in enterprise. Please also refer to your
response to comment 2 in your letter to us dated April 23, 2013.
Internet of Things Group, page 37
2. Please revise future filings to provide a clea r and quantifi ed discussion of the underlying
material causes of changes in the results you disclose. We note that your current
disclosure refers to general causes such as “higher IOTG platform unit sales” and “higher
IOTG platform average selling prices,” but does not explain the reasons for these changes
or quantify how each factor contributed to the period over period increases. Additionally,
if, as indicated in management’s 4th quarter earnings call, the changes to which you refer
were driven primarily by specific markets served by this group, please revise to clarify
the markets driving those changes and any material offsetting impact in other markets.
Provision for Income Taxes, page 41
3. We note the discussion of the decrease in your effective tax rate due to a higher
proportion of income generated in lower tax jurisdictions each period. We also note the
growing impact of non -U.S. income taxed at different rates on your effective tax rate
disclosed in Note 8 to your financial statements. In future f ilings please revise this section
to explain the impact of non -U.S. lower taxed jurisdictions on your effective tax rate,
including a discussion of the primary taxing jurisdictions where your foreign earnings are
derived, the location of tax holidays and t he relevant statutory rates in those
jurisdictions. Discuss any uncertainties relating to the income tax rates or benefits you
currently receive in those jurisdictions. Refer to Item 303(a)(3) of Regulation S -K.
We remind you that the company and its man agement 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 Kristin Lochhead at (202) 551 -3664 or Brian Cascio, Accounting
Branch Chief, at (202) 551 -3676 if you have questions regarding comments on the financial
statements and re lated matters. Please contact Geoff Kruczek , Special Counsel, at (202) 551 -
3641 or me at (202) 551 -3528 with any other questions.
Sincerely,
/s/ Amanda Ravitz
Amanda Ravitz
Assistant Director
Office of Electronics and Machinery