SEC Comment Letter 0000000000-22-013169 to ACCO BRANDS Corp (ACCO) (CIK 0000712034) (ACCO)
ACCO BRANDS Corp (ACCO) (CIK 0000712034)
Date: Dec. 7, 2022 · CIK: 0000712034 · Accession: 0000000000-22-013169
AI Filing Summary & Sentiment
File numbers found in text: 001-08454
Letter
United States securities and exchange commission logo December 7, 2022 Deborah O'Connor Chief Financial Officer ACCO Brands Corporation Four Corporate Drive Lake Zurich, Illinois 60047 Re:ACCO Brands Corporation Form 10-K for the Year Ended December 31, 2021 Filed February 23, 2022 File No. 001-08454 Dear Deborah O'Connor: We have reviewed your November 23, 2022 response to our comment letter and have the following comment. In our comment, 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. Unless we note otherwise, our references to prior comments are to comments in our October 26, 2022 letter. Form 10-K for the Year Ended December 31, 2021 Financial Statements Notes to Consolidated Financial Statements 19. Commitments and Contingencies, page 72 1.We note from your response to prior comment 3 that you recorded the $10.7 million in tax credits. However, it is unclear how it was recorded. In this regard, other income was credited in 2021, but the other side of the entry is unknown. Please tell us specifically where the tax credits were recorded in your financial statements upon receiving the decision and whether any reductions in taxes payable were recorded.
FirstName LastNameDeborah O'Connor Comapany NameACCO Brands Corporation December 7, 2022 Page 2 FirstName LastName Deborah O'Connor ACCO Brands Corporation December 7, 2022 Page 2 You may contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
December 7, 2022
Deborah O'Connor
Chief Financial Officer
ACCO Brands Corporation
Four Corporate Drive
Lake Zurich, Illinois 60047
Re:ACCO Brands Corporation
Form 10-K for the Year Ended December 31, 2021
Filed February 23, 2022
File No. 001-08454
Dear Deborah O'Connor:
We have reviewed your November 23, 2022 response to our comment letter and have the
following comment. In our comment, 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. Unless we note otherwise, our references to prior comments are to comments in our
October 26, 2022 letter.
Form 10-K for the Year Ended December 31, 2021
Financial Statements
Notes to Consolidated Financial Statements
19. Commitments and Contingencies, page 72
1.We note from your response to prior comment 3 that you recorded the $10.7 million in tax
credits. However, it is unclear how it was recorded. In this regard, other income was
credited in 2021, but the other side of the entry is unknown. Please tell us specifically
where the tax credits were recorded in your financial statements upon receiving the
decision and whether any reductions in taxes payable were recorded.
FirstName LastNameDeborah O'Connor
Comapany NameACCO Brands Corporation
December 7, 2022 Page 2
FirstName LastName
Deborah O'Connor
ACCO Brands Corporation
December 7, 2022
Page 2
You may contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing