SEC Comment Letter for TEXAS INSTRUMENTS INC (TXN) (CIK 0000097476) (TXN) — May 31, 2019
TEXAS INSTRUMENTS INC (TXN) (CIK 0000097476)
Date: May 31, 2019 · CIK: 0000097476 · Accession: 0000000000-19-009223
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-03761
Letter
May 31, 2019 Rafael R. Lizardi Chief Financial Officer Texas Instruments Incorporated 12500 TI Boulevard Dallas, TX 75243 Re:Texas Instruments Incorporated Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 22, 2019 File No. 001-03761 Dear Mr. Lizardi: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2018 Note 5. Income taxes, page 40 1.We note that in your U.S. statutory to effective income tax rate reconciliation you present a caption showing a 4.2% increase as result of U.S. Tax Act transitional non-cash expense. Please describe to us the transactions or circumstances that resulted in this reconciling item. Tell us whether this item relates to the withholding taxes in certain non- U.S. jurisdictions that will be incurred upon repatriation of available cash to the United States discussed on page 41. Revise future filings to provide similar clarifying disclosure.
FirstName LastNameRafael R. Lizardi Comapany NameTexas Instruments Incorporated May 31, 2019 Page 2 FirstName LastName Rafael R. Lizardi Texas Instruments Incorporated May 31, 2019 Page 2 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. You may contact Gary Newberry at (202) 551-3761 or Kevin Kuhar, Accounting Branch Chief, at (202) 551-3662 with any questions. Sincerely, Division of Corporation Finance Office of Electronics and Machinery
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May 31, 2019
Rafael R. Lizardi
Chief Financial Officer
Texas Instruments Incorporated
12500 TI Boulevard
Dallas, TX 75243
Re:Texas Instruments Incorporated
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 22, 2019
File No. 001-03761
Dear Mr. Lizardi:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to this comment 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 comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2018
Note 5. Income taxes, page 40
1.We note that in your U.S. statutory to effective income tax rate reconciliation you present
a caption showing a 4.2% increase as result of U.S. Tax Act transitional non-cash
expense. Please describe to us the transactions or circumstances that resulted in this
reconciling item. Tell us whether this item relates to the withholding taxes in certain non-
U.S. jurisdictions that will be incurred upon repatriation of available cash to the United
States discussed on page 41. Revise future filings to provide similar clarifying disclosure.
FirstName LastNameRafael R. Lizardi
Comapany NameTexas Instruments Incorporated
May 31, 2019 Page 2
FirstName LastName
Rafael R. Lizardi
Texas Instruments Incorporated
May 31, 2019
Page 2
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.
You may contact Gary Newberry at (202) 551-3761 or Kevin Kuhar, Accounting Branch
Chief, at (202) 551-3662 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery