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      Correspondence April 27 2007

              McDonald's
                Corporation

              2915
                Jorie Boulevard

              Oak
                Brook, IL  60523-1900

      April
        27,
        2007

      Ms.
        Linda
        Cvrkel

      Branch
        Chief

      Division
        of Corporation Finance

      U.S.
        Securities and Exchange Commission

      Washington,
        D.C. 20549

              RE:
              McDonald's
                Corporation

              Form
                10-K for the Fiscal Year Ended December 31,
                2006

              File
                No. 1-05231

      Dear
        Ms.
        Cvrkel:

      In
        reply
        to your further comments set out in your letter dated April 18, 2007, we
        have
        the following response.

      Notes
        to Consolidated Financial Statements, page 34

      Discontinued
        Operations, page 38

      1. Comment

      We
        note your response to our prior comment number 3 but do not concur with your
        conclusion that your disclosures pursuant to paragraph 47 of SFAS No.144
        were
        adequate given the overall materiality of the gain recognized on the disposition
        of Chipotle in your financial statements. Accordingly, please revise the
        notes
        to your financial statements in future filings to include the following
        disclosures:

              ·

                Please
                  disclose the facts and circumstances leading to the disposal of
                  Chipotle
                  as required by paragraph 47a of SFAS No.144. We do not believe
                  providing
                  these disclosures in MD&A or in previous SEC filings satisfies the
                  financial statement disclosure requirements outlined in SFAS
                  No.144.

              ·

                Please
                  disclose the revenue and pre-tax profit and loss of Chipotle reflected
                  in
                  discontinued operations for all periods presented. Although these
                  disclosures may not be material to your consolidated revenues and
                  consolidated pre-tax profit they presumably would be material to
                  the
                  segment results of the segment in which Chipotle was previously
                  included.

                Mr.
                  Matthew H. Paull

                McDonald's
                  Corporation

                April
                  27, 2007

                 2

              ·

                Please
                  explain in your future segment disclosures where Chipotle was previously
                  classified in your segment disclosures. Although you disclose in
                  a
                  footnote the assets of your discontinued operation, it is not apparent
                  from the disclosures provided in your “Segment and Geographic Information”
                  footnote where the Chipotle operations were previously classified.
                  Please
                  clarify this in your future segment
                  disclosures.

      Response

      As
        requested by the staff, we will revise the notes to the financial statements
        in
        future filings, starting with our Form 10-Q for the quarter ended March 31,
        2007, to include the facts and circumstances leading to disposal of Chipotle,
        the revenue and pre-tax profit of Chipotle and to identify the segment where
        Chipotle’s results were previously classified.

      If
        you
        have any questions on this letter or need further assistance, please call
        Pete
        Bensen, Corporate Senior Vice President - Controller, at (630) 623-3506 or
        me at
        (630) 623-7001.

      Sincerely,

      /S/
        Matthew H. Paull

      Matthew
        H. Paull

      Corporate
        Senior Executive Vice President and Chief Financial Officer

      cc:
        U.S.
        Securities and Exchange Commission

        Heather Clark

            McDonald’s
        Corporation

      Jim
        Skinner, Chief Executive Officer

      Pete
        Bensen, Corporate Senior

      Vice
        President - Controller