SEC Comment Letter for TAT TECHNOLOGIES LTD (TATT) (CIK 0000808439) (TATT) — Dec 22, 2016
TAT TECHNOLOGIES LTD (TATT) (CIK 0000808439)
Date: Dec. 22, 2016 · CIK: 0000808439 · Accession: 0000000000-16-106158
AI Filing Summary & Sentiment
File numbers found in text: 000-16050
Letter
Mail Stop 3561 December 22, 201 6 Guy Nathanzon Chief Financial Officer TAT Technologies Ltd. P.O. Box 80 Gedera 70750, Israel
Re: TAT Technologies Ltd. Form 20-F for Fiscal Y ear Ended December 31, 2015 Filed April 21, 201 6 File No. 000-16050 Form 6 -K Furnished November 18, 2016 File No. 000 -16050
Dear Mr. Nathanzon :
We have reviewed your filing an d 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 these comment s within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment s applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comment s, we may have additional comments.
Notes to Consolidated Financial Statements
Note 1: General, page F -11
1. We note your disclosure that t he accounting treatment for TAT -Engineering LLC will be based on the equity method despite your ownership o f 51% of the equity due to the participation rights given to your partner Engineering Holding of Moscow, Russia. Please tell us what those participation rights are and why you believe the equity method is appropriate.
Form 6 -K Furnished November 18, 2016
2. Based on information presented in the filing at and for the year ended December 31, 2015, the non -GAAP measure “EBITDA” you present appears to be derived from or based on a measure calculated and presented in accordance with generally accepted
Guy Nathanzon TAT Technologies Ltd. December 22, 2016 Page 2
accounting principles in the United States (“GAAP”). Please expand your presentation to provide a reconciliation between EBITDA and the most comparable financial measure calculated and presented in accordance with GAAP pursuant to Item 100(a)(2) of Regulation G.
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 Patrick Kuhn at (202) 551 -3308 or Doug Jones at (202) 551 -3309 with any questions . You may also call me at (202) 551 -3380.
Sincerely,
/s/ Lyn Shenk
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Mail Stop 3561 December 22, 201 6 Guy Nathanzon Chief Financial Officer TAT Technologies Ltd. P.O. Box 80 Gedera 70750, Israel Re: TAT Technologies Ltd. Form 20-F for Fiscal Y ear Ended December 31, 2015 Filed April 21, 201 6 File No. 000-16050 Form 6 -K Furnished November 18, 2016 File No. 000 -16050 Dear Mr. Nathanzon : We have reviewed your filing an d 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 these comment s within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment s applies to your facts and circumstances, please tell us why in your response. After reviewing your response to these comment s, we may have additional comments. Notes to Consolidated Financial Statements Note 1: General, page F -11 1. We note your disclosure that t he accounting treatment for TAT -Engineering LLC will be based on the equity method despite your ownership o f 51% of the equity due to the participation rights given to your partner Engineering Holding of Moscow, Russia. Please tell us what those participation rights are and why you believe the equity method is appropriate. Form 6 -K Furnished November 18, 2016 2. Based on information presented in the filing at and for the year ended December 31, 2015, the non -GAAP measure “EBITDA” you present appears to be derived from or based on a measure calculated and presented in accordance with generally accepted Guy Nathanzon TAT Technologies Ltd. December 22, 2016 Page 2 accounting principles in the United States (“GAAP”). Please expand your presentation to provide a reconciliation between EBITDA and the most comparable financial measure calculated and presented in accordance with GAAP pursuant to Item 100(a)(2) of Regulation G. 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 Patrick Kuhn at (202) 551 -3308 or Doug Jones at (202) 551 -3309 with any questions . You may also call me at (202) 551 -3380. Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief Office of Transportation and Leisure