SecProbe.io

December 4, 2012

Via E -mail
John B. Cozzolino
Chief Financial Officer
Albany International Corp.
216 Airport Dr.
Rochester, NH 03867

Re: Albany International Corp.
 Form 10-K for Fiscal Year Ended December 31, 2011
Filed February 28 , 2012
File No. 1 -10026

Dear Mr. Cozzolino :

We have reviewed your filing an d 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply t o your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comment s.

Form 10 -K for Fiscal Year Ended December 31, 2011

Selected Financial Data, page 23

1. Footnote two indicates that income tax expense in 2011 includes a favorable adjustment
of $3.5 million to correct errors from periods prior to 2006.  Sinc e the correction of these
errors appears to overstate fiscal 2011 net income by more than 10%, please better
explain to us how you determined it was appropriate to record this correction in 2011 and
why you did not record the error correction as an adjustm ent to prior periods.  Please tell
us in detail the nature of the error, when you first discovered the error and the quarterly
period in 2011 in which you recorded the error correction.  P lease also provide us with
your qualitative and quantitative assessm ent of materiality for each annual period in
which this error occurred and for 2011 to support your conclusion that these adjustments
are not material to your historical financial statements and that the correction of the error

John B. Cozzolino
Albany International Corp.
December 4, 2012
Page 2

 within your 2011 financial s tatements is appropriate.  Please refer to SAB Release No. 99
and 108.

Financial Statements for the Year Ended December 31, 2011

Notes to Consolidated Financial Statement, page 52

1. Accounting Policies, page 52

Revenue Recognition, page 52

2. We note that you r Engineered Composites segment  has long -term aerospace contracts
and capitalizes certain costs, such as engineering and equipment, during the phase in
which the production parts are designed and tested.  Citing authoritative accounting
guidance, p lease tell us how you determined capitalization of such costs was appropriate
and explain your methodology for recognizing these costs in income.
Discontinued Operations, page 53
3. We note that discontinued operations includes amounts previously reported as
“Unallocated expenses,” including expenses related to global information systems, and
certain interest expense when such expense results from direct third -party borrowings.
Please tell us the  nature of all “Unallocated expenses” that you include in discontinued
operations and tell us how your classification complies with GAAP.  In doing so, tell us if
any of the costs and expenses you include in discontinued operations are expected to
continue  subsequent to the disposal date.  Also tell us how your allocation of interest
expense complies with ASC 205 -20-45-6 through 45 -8.
3. Reportable Segments and Geographic Data, page 58
4. We note that during the third quarter of 2011, you announced plans to combine your
Paper Machine Clothing and Engineered Fabrics operating and reportable segments into a
single business segment.  Please explain to us in more detail how these former operating
and reportable segments now qualify as a single operating and repor table segment.  In
doing so, describe to us the specific nature of the information reviewed by your chief
operating decision maker under the former and current segment structures and, if
applicable, the extent to which your CODM now reviews stand -alone ope rating results of
the Paper Machine Clothing and Engineered Fabrics operations.

7. Income Taxes, page 70

5. We note that your reconciliation on page 71 of the U.S. federal statutory tax rate to your
effective income tax rate includes material adjustmen ts labeled “Foreign rate
differential.”  Please tell us whether or not this line item relates solely to differences in
foreign and domestic tax rates.  If particular countries contribute a disproportionately

John B. Cozzolino
Albany International Corp.
December 4, 2012
Page 3

 large amount of net income due to favorable tax rates, please disclose additional
information within MD&A about the tax structure of those countries and their impact on
your operations.  Consider disclosing pre -tax income and tax expense related to those
countries.

6. We note your disclosure on page 73 t hat, with certain exceptions, no provision has been
made for U.S. income taxes on the undistributed earnings of your foreign subsidiaries
since you intend to utilize those earnings in the foreign operations for an indefinite period
of time.  This disclosur e appears to contradict other statements made in your filing,
including your disclosure on page 73 that the repatriation of non -U.S. earnings will help
generate sufficient income to utilize certain deferred tax assets and your disclosure on
page 6 indicati ng that you have been able to repatriate earnings from the countries in
which you operate without substantial governmental restrictions and do not foresee any
material changes in your ability to do so in the future.  You also disclose on page 37 that
you m ade $45 million of repatriations during 2011, and on page 35 of your June 30, 2012
Form 10 -Q you indicate you were able to repay debt in 2012 due to your “ ability to
repatriate cash from non -U.S. acc ounts in a tax efficient manner.”  Since your disclosures
suggest that you regularly repatriate earnings from foreign subsidiaries, please tell us why
you generally believe that the undistributed earnings of your foreign subsidiaries are
permanently reinvested and no income taxes should be accrued.  See paragrap hs 3 and
17-19 of ASC 740 -30-25.  In addition, if a significant amount of your consolidated cash
is held overseas and is not available to the U.S. parent company due to permanent
reinvestment of foreign earnings, please revise your liquidity disclosures to  discuss the
nature of these restrictions and the impact on your liquidity.

7. We note your disclosure on pages 74 and 75 that you received reassessment notices from
the Canadian Revenue Agency (“CRA”) comprising tax, interest and penalties in the
amount of $61.6 million for the tax years 2001 through 2008.  We further note your
disclosure that although you believed these reassessments were substantially without
merit, you reached a settlement with the CRA in the first quarter of 2012 and “will record
the effect of this settlement in the first quarter of 2012.”  Please tell us whether you
accrued the amount of this settlement as of December 31, 2011.  If not, please provide us
with your analysis of why this subsequent event did not require adjustment to you r
December 31, 2011 financial statements prior to their release.  It appears the settlement
may have provided additional evidence with respect to conditions that existed at the
balance -sheet date and affected the estimates inherent in preparing your financ ial
statements.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

John B. Cozzolino
Albany International Corp.
December 4, 2012
Page 4

  In responding to our comments, please provide  a written st atement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Andrew Blume, Staff Accounta nt, at (202) 551 -3254 or me at (202)
551-3737  if you have questions regarding our comments or any other questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief