SecProbe.io

United States securities and exchange commission logo
June 8, 2023
Patrick W.D. McCann
Executive Vice-President and Chief Financial Officer
Magna International Inc.
337 Magna Drive
Aurora, Ontario, Canada L4G 7K1
Re:Magna International Inc.
Form 40-F for the Year Ended December 31, 2022
Filed March 31, 2023
Form 40-F/A for the Year Ended December 31, 2022
Filed April 27, 2023
File No. 001-11444
Dear Patrick W.D. McCann:
            We have limited our review of your filing to the financial statements and related
disclosures 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 40-F/A for the Year Ended December 31, 2022
Exhibit 2
Note 1. Significant Accounting Policies
Revenue Recognition, page 5
1.We note your discussion of the products offered by each of your reporting segments on
pages 31 through 38 of Exhibit 1.  Please tell us how you considered the guidance in ASC
606-10-50-5 when determining your disclosures related to the disaggregation of revenue
in your financial statements.  In addition, tell us how you considered the guidance in ASC
280-10-50-40 in concluding on the need to present revenues from external customers for
each product and service or each group of similar products and services.

 FirstName LastNamePatrick W.D. McCann
 Comapany NameMagna International Inc.
 June 8, 2023 Page 2
 FirstName LastName
Patrick W.D. McCann
Magna International Inc.
June 8, 2023
Page 2
Exhibit 3
Management's Discussion and Analysis of Results of Operations and Financial Position
Results of Operations, page 5
2.In future filings, please discuss in greater detail the business reasons for the changes
between periods in your sales and expense line items.  In addition, enhance your
disclosure to also discuss the business reasons for the changes between periods in the
significant line items of each of your segments.  In doing so, disclose the amount of each
significant change in line items between periods and the business reasons for it.  In
circumstances where there is more than one business reason for the change, quantify the
incremental impact of each individual business reason discussed on the overall change in
the line item.  For example, your disclosure on page 5 indicates that sales increased
primarily due to (i) the launch of new programs during or subsequent to 2021, (ii) higher
global light vehicle production and (iii) customer price increases to recover certain higher
production input costs, but it is unclear how significantly each of these factors impacted
your sales.  Please refer to Item 303(a)(3) of Regulation S-K for further information.
3.You state that you continue to experience elevated inflation in all markets in which you
operate, with higher commodity, energy, labour, freight and other production input pricing
expected to persist throughout 2023 and 2024.  In future filings, please expand to identify
the principal factors contributing to the inflationary pressures the company has
experienced and clarify the resulting impact to the company.
4.Please further discuss in future filings whether supply chain disruptions materially affect
your outlook or business goals.  Specify whether these challenges have materially
impacted your results of operations or capital resources and quantify, to the extent
possible, how your sales, profits, and/or liquidity have been impacted.
5.We note that you have experienced labour and other operational inefficiencies at your
facilities as a result of your production lines being stopped/started largely due to supply
constraints.  Please revise your disclosure in future filings to discuss known trends or
uncertainties resulting from mitigation efforts undertaken, if any.  Explain whether any
mitigation efforts introduce new material risks, including those related to product quality,
reliability, or regulatory approval of products.

 FirstName LastNamePatrick W.D. McCann
 Comapany NameMagna International Inc.
 June 8, 2023 Page 3
 FirstName LastName
Patrick W.D. McCann
Magna International Inc.
June 8, 2023
Page 3
            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 Jeffrey Gordon at 202-551-3866 or Martin James at 202-551-3671 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing