SEC Comment Letter for ICAHN ENTERPRISES L.P. (IEP) (CIK 0000813762) (IEP) — Aug 21, 2017
ICAHN ENTERPRISES L.P. (IEP) (CIK 0000813762)
Date: Aug. 21, 2017 · CIK: 0000813762 · Accession: 0000000000-17-029507
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-118021
Letter
Mail Stop 3561 Augus t 21, 2017 SungHwan Cho Chief Financial Officer Icahn Enterprises L.P. Icahn Enterprises Holdings L.P. 767 Fifth Avenue, Suite 4700 New York, NY 10153
Re: Icahn Enterprises L.P. Icahn Enterprises Holdings L .P. Form 10 -K for Fiscal Year Ended December 31, 2016 Response dated August 10, 2017 File No. 001 -09516 File No. 333-118021 -01
Dear Mr. Cho:
We have reviewed your August 10, 2017 response to our comment letter 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 busine ss days by providing th e requested information or advis e 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 Fiscal Year Ended December 31, 2016
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations , Investment, page 108
1. We have reviewed your response to prior c omment 1 and also the proposed revision to the narrative discussion of the Investment Funds’ performance attribution. Please give consideration to further expanding this discussion to identify those individual securities or class of securities (e.g., basi c materials, consumer, non -cyclical, energy, financial, etc.) that were in a short or long position and had a material impact on the Investment
SungHwan Cho Icahn Enterprises L.P. Icahn Enterprises Holdings L.P. August 21, 2017 Page 2
segment’s net loss and the reason(s) underlying material changes in their net income (loss) from investment acti vities. For example, please discuss your investments held in Herbalife Ltd. and Hertz Global Holdings, Inc. and the significant losses recorded in the Investment segment for fiscal year 2016 pertaining to these two securities. Reference is made to financ ial statement note 5, Investments and Related Matters, at page 173, and also to the sample listing of individual securities held in the Investment segment disclosed in the second to the last paragraph of page 1 of the 2016 Annual Report on Form 10 -K.
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 Beverly A. Singleton at (202) 551 -3328 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3379 with any other questions.
Sincerely,
/s/ Melissa Raminpour
Show Raw Text
Mail Stop 3561 Augus t 21, 2017 SungHwan Cho Chief Financial Officer Icahn Enterprises L.P. Icahn Enterprises Holdings L.P. 767 Fifth Avenue, Suite 4700 New York, NY 10153 Re: Icahn Enterprises L.P. Icahn Enterprises Holdings L .P. Form 10 -K for Fiscal Year Ended December 31, 2016 Response dated August 10, 2017 File No. 001 -09516 File No. 333-118021 -01 Dear Mr. Cho: We have reviewed your August 10, 2017 response to our comment letter 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 busine ss days by providing th e requested information or advis e 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 Fiscal Year Ended December 31, 2016 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations , Investment, page 108 1. We have reviewed your response to prior c omment 1 and also the proposed revision to the narrative discussion of the Investment Funds’ performance attribution. Please give consideration to further expanding this discussion to identify those individual securities or class of securities (e.g., basi c materials, consumer, non -cyclical, energy, financial, etc.) that were in a short or long position and had a material impact on the Investment SungHwan Cho Icahn Enterprises L.P. Icahn Enterprises Holdings L.P. August 21, 2017 Page 2 segment’s net loss and the reason(s) underlying material changes in their net income (loss) from investment acti vities. For example, please discuss your investments held in Herbalife Ltd. and Hertz Global Holdings, Inc. and the significant losses recorded in the Investment segment for fiscal year 2016 pertaining to these two securities. Reference is made to financ ial statement note 5, Investments and Related Matters, at page 173, and also to the sample listing of individual securities held in the Investment segment disclosed in the second to the last paragraph of page 1 of the 2016 Annual Report on Form 10 -K. 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 Beverly A. Singleton at (202) 551 -3328 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3379 with any other questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Transportation and Leisure