SEC Company Response from Stagwell Inc (STGW) (CIK 0000876883) (STGW) — Mar 13, 2009
Stagwell Inc (STGW) (CIK 0000876883)
Date: March 13, 2009 · CIK: 0000876883 · Accession: 0001144204-09-013746
AI Filing Summary & Sentiment
Reasoning
Letter
Division of Corporation Finance Securities and Exchange Commission Form 10-K for Fiscal Year Ended December 31, 2007 Filed March 10, 2008 Form 10-Q Fiscal Quarter Ended September 30, 2008 File No. 1-13718
Dear Mr. Spirgel:
Pursuant to your request following our telephonic conversation on March 3, 2009, the Company intends to apply FASB statement 160 and EITF Topic D-98 by recording the estimated Put redemption amount as of January 1, 2009 as a credit to (increase in) Redeemable Non-controlling Interests (minority interests), in a mezzanine account above Shareholders’ Equity, and a debit to (reduction of) Additional Paid-in Capital, a component of Shareholders’ Equity. As of January 1, 2009, the Company has an Accumulated Deficit. The Company believes that because of the redeemable nature of the Non-controlling Interests, this amount should not be a component of Shareholders’ Equity. In addition, the estimated redemption amounts will be recalculated each reporting period with any changes to the estimate again adjusting Redeemable Non-controlling Interests and Additional Paid-in Capital. These adjustments, if any, will not be used to calculate earnings per share. However, the Company will continue to test at each reporting period to ensure that the estimated amount of the Put redemption is not greater than the current fair market value of the specifically related entity. If the estimated redemption amount is greater than current fair market value the Company will record that excess amount as a credit to (increase in) Redeemable Non-controlling Interests on the balance sheet and a debit to (charge to) the Non-controlling Interests in the statement of operations. The Company does not anticipate that the estimated redemption amounts would be greater than fair market value; however, the Company believes that this is a proper accounting policy to follow.
* * * *
Very
truly yours,
/s/ David
Doft
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CORRESP
1
filename1.htm
March 12,
2009
Via FedEx and
Edgar
Mr. Larry
Spirgel
Assistant
Director
Mail Stop
0407
Division
of Corporation Finance
Securities
and Exchange Commission
450 Fifth
Street, N.W.
Washington,
D.C. 20549
RE:
MDC
Partners, Inc.
Form
10-K for Fiscal Year Ended December 31, 2007
Filed
March 10, 2008
Form
10-Q Fiscal Quarter Ended September 30, 2008
File
No. 1-13718
Dear Mr.
Spirgel:
Pursuant
to your request following our telephonic conversation on March 3, 2009, the
Company intends to apply FASB statement 160 and EITF Topic D-98 by recording the
estimated Put redemption amount as of January 1, 2009 as a credit to (increase
in) Redeemable Non-controlling Interests (minority interests), in a mezzanine
account above Shareholders’ Equity, and a debit to (reduction of) Additional
Paid-in Capital, a component of Shareholders’ Equity. As of January 1, 2009, the
Company has an Accumulated Deficit. The Company believes that because of the
redeemable nature of the Non-controlling Interests, this amount should not be a
component of Shareholders’ Equity. In addition, the estimated redemption amounts
will be recalculated each reporting period with any changes to the estimate
again adjusting Redeemable Non-controlling Interests and Additional Paid-in
Capital. These adjustments, if any, will not be used to calculate earnings per
share. However, the Company will continue to test at each reporting period to
ensure that the estimated amount of the Put redemption is not greater than the
current fair market value of the specifically related entity. If the estimated
redemption amount is greater than current fair market value the Company will
record that excess amount as a credit to (increase in) Redeemable
Non-controlling Interests on the balance sheet and a debit to (charge to) the
Non-controlling Interests in the statement of operations. The Company does not
anticipate that the estimated redemption amounts would be greater than fair
market value; however, the Company believes that this is a proper accounting
policy to follow.
* * * *
Very
truly yours,
/s/ David
Doft
David
Doft
Chief
Financial Officer
Enclosure
cc:
Melissa
Hauber
Robert S. Littlepage, Jr.
Securities
and Exchange Commission
Miles S.
Nadal, Chairman and Chief Executive Officer
Mitchell
Gendel, General Counsel & Corporate Secretary
Michael
Sabatino, Chief Accounting Officer
Members
of the Audit Committee of Board of Directors of MDC Partners Inc.
Joseph Klausner, BDO Seidman
LLP
Ethan Klingsberg, Esq., Cleary Gottlieb
Steen & Hamilton LLP