SEC Comment Letter for MAXIM INTEGRATED PRODUCTS INC (CIK 0000743316) — Feb 6, 2020
MAXIM INTEGRATED PRODUCTS INC (CIK 0000743316)
Date: Feb. 6, 2020 · CIK: 0000743316 · Accession: 0000000000-20-001183
AI Filing Summary & Sentiment
File numbers found in text: 001-34192
Letter
February 6, 2020 Brian C. White Chief Financial Officer Maxim Integrated Products, Inc. 160 Rio Robles San Jose, CA 95134 Re:Maxim Integrated Products, Inc. Form 10-K for the Fiscal Year Ended June 29, 2019 Form 10-Q for the Period Ended December 28, 2019 File No. 001-34192 Dear Mr. White: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended June 29, 2019 Notes to Consolidated Financial Statements Note 15: Income Taxes, page 67 1.We note the reversal of $221.5 million of your tax reserves primarily due to the settlement of an audit of your fiscal year 2009 through 2011 federal corporate income tax returns. We also note your disclosure in prior filings that in May 2018, a preliminary understanding was reached with the IRS regarding the contested issues for the audit and post-audit years. Please tell us and disclose in more detail the reason for the significant change in amounts from the preliminary understanding to the final settlement.
FirstName LastNameBrian C. White Comapany NameMaxim Integrated Products, Inc. February 6, 2020 Page 2 FirstName LastName Brian C. White Maxim Integrated Products, Inc. February 6, 2020 Page 2 Form 10-Q for the Period Ended December 28, 2019 Notes to Condensed Consolidated Financial Statements Note 8: Segment Information, page 18 2.We note your disaggregated revenue disclosure of revenue by geographic region in Note 8. Please tell us your consideration for disclosing further disaggregation of revenue for your major end-markets noted on page 24. We note your discussion of changes in net revenues for these markets in your results of operations in your MD&A disclosures as well as related discussions on your earnings calls and slide decks. Please refer to ASC 606-10-55-90 and 91. 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 Melisa Gilmore at (202) 551-3777 or Melissa Raminpour at (202) 551- 3379 if you have any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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February 6, 2020
Brian C. White
Chief Financial Officer
Maxim Integrated Products, Inc.
160 Rio Robles
San Jose, CA 95134
Re:Maxim Integrated Products, Inc.
Form 10-K for the Fiscal Year Ended June 29, 2019
Form 10-Q for the Period Ended December 28, 2019
File No. 001-34192
Dear Mr. White:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended June 29, 2019
Notes to Consolidated Financial Statements
Note 15: Income Taxes, page 67
1.We note the reversal of $221.5 million of your tax reserves primarily due to the settlement
of an audit of your fiscal year 2009 through 2011 federal corporate income tax returns.
We also note your disclosure in prior filings that in May 2018, a preliminary
understanding was reached with the IRS regarding the contested issues for the audit and
post-audit years. Please tell us and disclose in more detail the reason for the significant
change in amounts from the preliminary understanding to the final settlement.
FirstName LastNameBrian C. White
Comapany NameMaxim Integrated Products, Inc.
February 6, 2020 Page 2
FirstName LastName
Brian C. White
Maxim Integrated Products, Inc.
February 6, 2020
Page 2
Form 10-Q for the Period Ended December 28, 2019
Notes to Condensed Consolidated Financial Statements
Note 8: Segment Information, page 18
2.We note your disaggregated revenue disclosure of revenue by geographic region in Note
8. Please tell us your consideration for disclosing further disaggregation of revenue for
your major end-markets noted on page 24. We note your discussion of changes in net
revenues for these markets in your results of operations in your MD&A disclosures as
well as related discussions on your earnings calls and slide decks. Please refer to ASC
606-10-55-90 and 91.
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 Melisa Gilmore at (202) 551-3777 or Melissa Raminpour at (202) 551-
3379 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing