SEC Comment Letter for Johnson Controls International plc (JCI) (CIK 0000833444) (JCI) — Feb 23, 2018
Johnson Controls International plc (JCI) (CIK 0000833444)
Date: Feb. 23, 2018 · CIK: 0000833444 · Accession: 0000000000-18-006030
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13836
Letter
February 23, 2018 Brian Stief Executive Vice President and Chief Financial Officer Johnson Controls International plc One Albert Quay Cork, Ireland Re:Johnson Controls International plc Form 10-K for the Fiscal Year Ended September 30, 2017 Filed November 21, 2017 File No. 001-13836 Dear Mr. Stief: We have reviewed your filing and have the following comment. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended September 30, 2017 18. Income Taxes, page 114 1.We note your disclosure stating "the U.S. federal statutory tax rate is being used as a comparison since the Company was a U.S. domiciled company in fiscal 2015 and 11 months of 2016 and due to the Company's current legal entity structure." Given that you were re-domiciled in Ireland in September 2016, please present your reconciliation of the statutory tax rate to the effective tax rate using the statutory tax rate of your country of domicile. Refer to Rule 4-08(h)(2) of Regulation S-X. 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.
FirstName LastNameBrian Stief Comapany NameJohnson Controls International plc June 16, 2017 Page 2 FirstName LastName Brian Stief Johnson Controls International plc February 23, 2018 Page 2 You may contact Kathryn Jacobson, Senior Staff Accountant, at 202-551-3365 or Robert Littlepage, Accountant Branch Chief, at 202-551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Courtney Lindsay, Staff Attorney, at 202-551-7237 or Celeste Murphy, Legal Branch Chief, at 202-551-3257 with any other questions. Division of Corporation Finance AD 11- Office of Telecommunications
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February 23, 2018
Brian Stief
Executive Vice President and Chief Financial Officer
Johnson Controls International plc
One Albert Quay
Cork, Ireland
Re:Johnson Controls International plc
Form 10-K for the Fiscal Year Ended September 30, 2017
Filed November 21, 2017
File No. 001-13836
Dear Mr. Stief:
We have reviewed your filing and have the following comment. Please comply with the
following comment in future filings. Confirm in writing that you will do so and explain to us
how you intend to comply.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended September 30, 2017
18. Income Taxes, page 114
1.We note your disclosure stating "the U.S. federal statutory tax rate is being used as a
comparison since the Company was a U.S. domiciled company in fiscal 2015 and 11
months of 2016 and due to the Company's current legal entity structure." Given that you
were re-domiciled in Ireland in September 2016, please present your reconciliation of the
statutory tax rate to the effective tax rate using the statutory tax rate of your country of
domicile. Refer to Rule 4-08(h)(2) of Regulation S-X.
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.
FirstName LastNameBrian Stief
Comapany NameJohnson Controls International plc
June 16, 2017 Page 2
FirstName LastName
Brian Stief
Johnson Controls International plc
February 23, 2018
Page 2
You may contact Kathryn Jacobson, Senior Staff Accountant, at 202-551-3365 or Robert
Littlepage, Accountant Branch Chief, at 202-551-3361 if you have questions regarding
comments on the financial statements and related matters. Please contact Courtney Lindsay,
Staff Attorney, at 202-551-7237 or Celeste Murphy, Legal Branch Chief, at 202-551-3257 with
any other questions.
Division of Corporation Finance
AD 11- Office of
Telecommunications