SEC Comment Letter for LIONS GATE ENTERTAINMENT (STRZ) — Mar 10, 2016
LIONS GATE ENTERTAINMENT CORP /CN/ (STRZ, LGF-A, LGF-B) (CIK 0000929351)
Date: March 10, 2016 · CIK: 0000929351 · Accession: 0000000000-16-067935
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 March 10, 2016 James W. Barge Chief Financial Officer Lions Gate Entertainment Corp. 2700 Colorado Avenue , Suite 5000 Santa Monica, CA 90404
Re: Lions Gate Entertainment Corp. Form 10-K for the Fiscal Year Ended March 31, 2015 Response Dated March 4, 2016 File No. 001 -14880
Dear Mr. Barge :
We have reviewed your March 4, 2016 response to our comment letter and 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 comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will res pond. 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. Unless we note otherwise, our references to prior comments are to comments in our February 22, 2016 letter .
Notes to Audited Consolidated Financial Statements
12. Income Taxes, page F -36
1. We note from your response to our prior comment 2 that the foreign rate differential reconciling item in fiscal 2015 is primarily driven by the Canadian tax laws, particularly the favorable permanent book -tax difference for certain foreign affiliate dividends. Please revise your disclosure in Note 12 to clearly explain the nature of this significant reconciling item .
James W. Barge Lions Gate Entertainment Corp. March 10, 2016 Page 2
You may contact Melissa Gilmore at (202) 551 -3777 or Claire Erlanger at (202) 551 - 3301 with any other questions.
Sincerely,
/s/ Melissa Raminpour
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Mail Stop 3561 March 10, 2016 James W. Barge Chief Financial Officer Lions Gate Entertainment Corp. 2700 Colorado Avenue , Suite 5000 Santa Monica, CA 90404 Re: Lions Gate Entertainment Corp. Form 10-K for the Fiscal Year Ended March 31, 2015 Response Dated March 4, 2016 File No. 001 -14880 Dear Mr. Barge : We have reviewed your March 4, 2016 response to our comment letter and 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 comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will res pond. 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. Unless we note otherwise, our references to prior comments are to comments in our February 22, 2016 letter . Notes to Audited Consolidated Financial Statements 12. Income Taxes, page F -36 1. We note from your response to our prior comment 2 that the foreign rate differential reconciling item in fiscal 2015 is primarily driven by the Canadian tax laws, particularly the favorable permanent book -tax difference for certain foreign affiliate dividends. Please revise your disclosure in Note 12 to clearly explain the nature of this significant reconciling item . James W. Barge Lions Gate Entertainment Corp. March 10, 2016 Page 2 You may contact Melissa Gilmore at (202) 551 -3777 or Claire Erlanger at (202) 551 - 3301 with any other questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Transportation and Leisure