SecProbe.io

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Mail Stop 7010

      July 13, 2005

Mr. Michael S. Poteshman
Executive Vice President and CFO
Tupperware Corporation
14901 South Orange Blossom Trail
Orlando, FL  32837

	RE:	Form 10-K for the fiscal year ended December 25, 2004
		Form 10-Q for the quarter ended April 2, 2005
		File No. 1-11657

Dear Mr. Poteshman:

      We have reviewed these filings and have the following
comments.
If you disagree with a comment, we will consider your explanation
as
to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure.  After reviewing this
information,
we may or may not raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM 10-K FOR THE YEAR ENDED DECEMBER 25, 2004

General
1. Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like.  These revisions should be
included in your future filings.

Selected Financial Data, page 7

2. You present total segment profit here and elsewhere throughout
the
filing.  Since total segment profit represents a non-GAAP measure
when it is presented or discussed outside of your SFAS 131
footnote,
you should ensure either:
(a) it is not presented elsewhere in the filing or
(b) you present the disclosures required by Item 10(e) of
Regulation
S-K.  Any disclosures elsewhere in the filing should:
* reconcile from total segment profit to operating income and then
on
to net income to highlight the differences between the non-GAAP
measure and operating income,
* identify this amount as a non-GAAP performance measure,
* state the material limitations associated with use of the non-
GAAP
financial measure as compared to the use of the most directly
comparable GAAP financial measure,
* state the manner in which management compensates for these
limitations when using the non-GAAP financial measure,
* explain why your management believes that this measure provides
useful information to investors,
* state how your management uses the non-GAAP measure,
* provide cautionary disclosure that the non-GAAP measure
presented
may not be comparable to similarly titled measures used by other
entities and
* state that this non-GAAP measure should not be considered as an
alternative to net income, which is determined in accordance with
GAAP.
See also Question 21 of our FAQ Regarding the Use of Non-GAAP
Financial Measures dated June 13, 2003.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Financial Condition, page 19

3. Please present reconciliations, here and elsewhere throughout
the
filing where you have presented the ratios, to show how the
following
ratios are computed:
* Interest coverage ratio
* Leverage ratio
* Adjusted net worth ratio
* Fixed charge to coverage ratio
* Adjusted EBITDA
In addition, adjusted EBITDA represents a non-GAAP measure.
Please
identify the item as a non-GAAP measure and provide cautionary
disclosure that the non-GAAP measure presented may not be
comparable
to similarly titled measures used by other entities.

Market Risk, page 24

4. You disclose that you entered into eight option agreements with
a
combined notional value of approximately 49.4 million euro that
expire at various points during 2004.  Please confirm the year of
expiration or revise accordingly.

Financial Statements

Statement of Cash Flows, page 32

5. Please breakout for each period presented the other-net line
item
in the cash provided by operating activities sections into smaller
components having more descriptive titles.  Netting of dissimilar
gains and losses is not appropriate.  Netting of cash flows
related
to asset balances with cash flows related to liability balances is
also not appropriate.  See SFAS 95.

Note 1 - Summary of Significant Accounting Policies

6. Please disclose the types of expenses that you include in the
cost
of products sold line item and the types of expenses that you
include
in the delivery, sales and administrative expenses line item.
Please
also disclose whether you include inbound freight charges,
purchasing
and receiving costs, inspection costs, warehousing costs, internal
transfer costs, and the other costs of your distribution network
in
the cost of products sold line item.  With the exception of
warehousing costs, if you currently exclude a portion of these
costs
from cost of products sold, please disclose:
* in a footnote the line items that these excluded costs are
included
in and the amounts included in each line item for each period
presented, and
* in MD&A that your gross margins may not be comparable to those
of
other entities, since some entities include all of the costs
related
to their distribution network in cost of products sold and others
like you exclude a portion of them from gross margin, including
them
instead in a line item such as delivery, sales and administrative
expenses.

Property, Plant and Equipment, page 34

7. The range of useful lives for your machinery and equipment of
three to twenty years is very broad.  Please breakout the
machinery
and equipment category in the table to Note 4 into smaller
components.  Please disclose the range of useful lives for each
revised category presented in Note 4.  For categories that still
have
very broad useful lives, you should separately discuss the types
of
assets that fall in each part of the range.

Promotional and Other Accruals, page 34

8. You make promotional offers to members of your independent
sales
force.  Please disclose how these arrangements are typically
structured.  If you also pay cooperative advertising fees,
slotting
fees, have buydown programs, and/or make other payments to
resellers,
please provide similar disclosures regarding each of these types
of
arrangements, and disclose your accounting policy for them,
including
the statement of operations line item in which they are included.
For each expense line item that includes these types of
arrangements,
please disclose the related amounts included in that line item.
For
each type of arrangement treated as an expense rather than as a
reduction of revenue, please tell us how this type of arrangement
meets the requirements in EITF 01-9.  Please also discuss in MD&A
any
significant estimates resulting from these arrangements.

Net Income Per Common Share, page 36

9. Please disclose how you are treating the restricted shares you
have issued in computing both your basic and diluted earnings per
share.  See paragraphs 10 and 13 of SFAS 128.

Note 6 - Financing Arrangements, page 39

10. Please retitle the measure you currently call EBITDA here and
elsewhere throughout the filing, since you are including other
non-
cash charges in this measure.  See Question 14 of our FAQ
Regarding
the Use of Non-GAAP Financial Measures dated June 13, 2003.

Note 14 - Commitments and Contingencies, page 51

11. Please disclose how you account for (a) step rent provisions
and
escalation clauses and (b) capital improvement funding and other
lease concessions, which may be present in your leases. Paragraph
5.n. of SFAS 13, as amended by SFAS 29, discusses how lease
payments
that depend on an existing index or rate, such as the consumer
price
index or the prime interest rate, should also be included in your
minimum lease payments.  If, as we assume, they are taken into
account in computing your minimum lease payments and the minimum
lease payments are recognized on a straight-line basis over the
minimum lease term, the note should so state.  If our assumption
is
incorrect, please tell us how your accounting complies with SFAS
13
and FTB 88-1.

12. Please include the disclosures required by paragraphs 16.c.
and
d. of SFAS 13 regarding your operating leases.

FORM 10-Q FOR THE PERIOD ENDED APRIL 2, 2005

General

13. Please address the above comments in your interim filings as
well.

*    *    *    *

      Please respond to these comments within 10 business days, or
tell us when you will provide us with a response.  Please provide
us
with a response letter that keys your responses to our comments
and
provides any requested information.  Detailed letters greatly
facilitate our review.  Please file your supplemental response on
EDGAR as a correspondence file.  Please understand that we may
have
additional comments after reviewing your responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information required under the
Securities Exchange Act of 1934 and that they have provided all
information investors require for an informed decision.  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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;

* 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.

		In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

      If you have any questions regarding these comments, please
direct them to Jeffrey Gordon, Staff Accountant, at (202) 551-3866
or, in his absence, to the undersigned at (202) 551-3769.

							Sincerely,

							Rufus Decker
							Accounting Branch Chief

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Mr. Michael S. Poteshman
Tupperware Corporation
July 13, 2005
Page 1 of 6

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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