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SEC Comment Letter for SMITH A O (AOS) — Apr 21, 2026

SMITH A O CORP
Date: April 21, 2026 · CIK: 0000091142 · Accession: 0000000000-26-004028

Financial Reporting Regulatory Compliance Revenue Recognition

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Document Type
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Reasoning

File numbers found in text: 001-00475

Date
April 21, 2026
Author
Division of Corporation Finance
Form
UPLOAD
Company
SMITH A O CORP

Letter

Re: A.O. Smith Corporation Form 10-K for the year ended December 31, 2025 File No. 001-00475 Dear Charles Lauber:

April 21, 2026

Charles Lauber Chief Financial Officer A.O. Smith Corporation 11270 West Park Place Milwaukee, Wisconsin 53224

We have limited our review of your filing to the financial statements and related disclosures and have the following comment.

Please respond to this letter 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 letter, we may have additional comments.

Form 10-K for the year ended December 31, 2025 Income Taxes, page 50

1. Your MD&A attributes the 2025 effective tax rate change to reduced U.S. cross-border taxes, yet your rate reconciliation lacks a corresponding category. Additionally, you cite a one-time tax adjustment from a tax law change as a cash flow benefit, but this is not separately identified in your reconciliation as required by ASC 740-10-50-12A(a). Please tell us and disclose in future filings the details of the specific tax law change. Also, clarify how these items are currently reflected in your reconciliation and why they do not warrant separate presentation. 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.

Please contact Charles Eastman at 202-551-3794 or Melissa Gilmore at 202-551-3777 with any questions. April 21, 2026 Page 2

Sincerely,
Division of Corporation Finance
Office of Manufacturing

Show Raw Text
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<TEXT>
 April 21, 2026

Charles Lauber
Chief Financial Officer
A.O. Smith Corporation
11270 West Park Place
Milwaukee, Wisconsin 53224

 Re: A.O. Smith Corporation
 Form 10-K for the year ended December 31, 2025
 File No. 001-00475
Dear Charles Lauber:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

 Please respond to this letter 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 letter, we may have additional
comments.

Form 10-K for the year ended December 31, 2025
Income Taxes, page 50

1. Your MD&A attributes the 2025 effective tax rate change to reduced U.S.
cross-border
 taxes, yet your rate reconciliation lacks a corresponding category.
Additionally, you cite
 a one-time tax adjustment from a tax law change as a cash flow
benefit, but this is not
 separately identified in your reconciliation as required by ASC
740-10-50-12A(a). Please
 tell us and disclose in future filings the details of the specific tax
law change. Also,
 clarify how these items are currently reflected in your reconciliation
and why they do not
 warrant separate presentation.
 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.

 Please contact Charles Eastman at 202-551-3794 or Melissa Gilmore at
202-551-3777
with any questions.
 April 21, 2026
Page 2

 Sincerely,

 Division of Corporation Finance
 Office of Manufacturing
</TEXT>
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