SEC Comment Letter for THERMO FISHER SCIENTIFIC INC. (TMO) (CIK 0000097745) (TMO) — May 30, 2013
THERMO FISHER SCIENTIFIC INC. (TMO) (CIK 0000097745)
Date: May 30, 2013 · CIK: 0000097745 · Accession: 0000000000-13-029589
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Letter
May 30, 2013 Via E -Mail Mr. Peter M. Wilver Senior Vice President and Chief Financial Officer Thermo Fisher Scientific Inc. 81 Wyman Street Waltham, MA 02451
Re: Thermo Fisher Scientific Inc. Form 10-K for the year ended December 31, 201 2 Filed February 27 , 2013 File No. 1-08002
Dear Mr. Wilver :
We have reviewed your response dated May 7, 2013 and filing s and have the following comment s. 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 letter within ten business days by providing the requested information or by advising us when you will provide t he requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2012
Item 8. Financial Statements
Note 7. Income Taxes, page F -40
1. We note that within your effective tax rate reconciliation, the impact of the foreign rate differential is significant in each year. Please tell u s the countries for which the significant portion of this item relates and quantify to the extent practicable. In future filings, revise the income tax di scussions in M anagement ’s Discus sion and Analysis to provide a robust discussion of your tax position s in these foreign tax jurisdiction s and how they have impacted, and will impact in future periods , your income tax provision and net income . Refer to I tem 303(a)(3)(i) of Regulation S -K.
Mr. Peter M. Wilver Thermo Fisher Scientific Inc. May 30, 201 3 Page 2
You may contact David Burton, Staff Accountant , at (202) 551 -3626 or Kate Tillan, Assistant Chief Accountant , at (202) 551 -3604 if you ha ve questions regarding these comments. In this regard, do not hesitate to contact me at (202) 551 -3671.
Sincerely,
/s/ Martin James
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May 30, 2013
Via E -Mail
Mr. Peter M. Wilver
Senior Vice President and Chief Financial Officer
Thermo Fisher Scientific Inc.
81 Wyman Street
Waltham, MA 02451
Re: Thermo Fisher Scientific Inc.
Form 10-K for the year ended December 31, 201 2
Filed February 27 , 2013
File No. 1-08002
Dear Mr. Wilver :
We have reviewed your response dated May 7, 2013 and filing s and have the following
comment s. 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 letter within ten business days by providing the requested
information or by advising us when you will provide t he requested response. If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2012
Item 8. Financial Statements
Note 7. Income Taxes, page F -40
1. We note that within your effective tax rate reconciliation, the impact of the foreign rate
differential is significant in each year. Please tell u s the countries for which the
significant portion of this item relates and quantify to the extent practicable. In future
filings, revise the income tax di scussions in M anagement ’s Discus sion and Analysis to
provide a robust discussion of your tax position s in these foreign tax jurisdiction s and
how they have impacted, and will impact in future periods , your income tax provision
and net income . Refer to I tem 303(a)(3)(i) of Regulation S -K.
Mr. Peter M. Wilver
Thermo Fisher Scientific Inc.
May 30, 201 3
Page 2
You may contact David Burton, Staff Accountant , at (202) 551 -3626 or Kate Tillan,
Assistant Chief Accountant , at (202) 551 -3604 if you ha ve questions regarding these comments.
In this regard, do not hesitate to contact me at (202) 551 -3671.
Sincerely,
/s/ Martin James
Martin James
Senior Assistant Chief Accountant
cc (e -mail): Peter E. Hornstra
Chief Accounting Officer