SEC Comment Letter for COTY INC. (COTY) (CIK 0001024305) (COTY) — Jul 2, 2015
COTY INC. (COTY) (CIK 0001024305)
Date: July 2, 2015 · CIK: 0001024305 · Accession: 0000000000-15-034745
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 20, 2015
Letter
July 2 , 2015 Via E -mail Mr. Patrice de Talhouët Chief Financial Officer Coty Inc. 350 Fifth Avenue New York, NY 10118
Re: Coty Inc. Form 10-K for the Fiscal Year Ended June 30, 2014 Filed August 28, 2014 Form 10 -Q for the Fiscal Period Ended March 31, 2015 Filed May 7 , 2015 Response D ated June 3 , 2015 File No. 1 -35964
Dear Mr. de Talhouët :
We have reviewed your response dated June 3 , 2015 and have the following comment .
Please respond to this comment within ten busine ss days by providing the requested information or advis e 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 yo ur response.
After reviewing your response to this comment , we may have additional comments.
Form 10 -Q for the Period Ended March 31, 2015
Management’s Discussion and Analysis of Financial Condition…, page 27
Liquidity and Capital Resources, page 43
We note your response to comment three from our letter dated May 20, 2015. Please address the following: Explain whether or not you consider the transfer of $373.5 million in foreign cash/earnings to the U.S. parent company to be a rep atriation, including the basis for your position; If the transaction was structured, in part, to enable the U.S. parent company to gain access to foreign cash/earnings without accruing U.S. taxes upon repatriation, disclose that fact and quantify the tax savings achieved as a result of using this strategy; and
Patrice de Talhouët Coty Inc. July 2 , 2015 Page 2
Explain if the use of this strategy is expected to have a material impact on your unrealized tax benefits as of June 30, 2015 and, if applicable, ensure your financial statement footnotes address the impact.
You may contact Lisa Etheredge, Staff Accountant, at (202) 551 -3424 or Anne McConnell, Staff Accountant, at (202) 551 -3709 if you have questions regarding comments on the financial statements and related matters. Please contact Edward M. Kelly, Senior Counsel, at (202) 551 -3728 or Pamela Long, Assistant Director, at (202) 551 -3765 with any other questions.
Sincerely,
/s/ Pamela Long
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July 2 , 2015 Via E -mail Mr. Patrice de Talhouët Chief Financial Officer Coty Inc. 350 Fifth Avenue New York, NY 10118 Re: Coty Inc. Form 10-K for the Fiscal Year Ended June 30, 2014 Filed August 28, 2014 Form 10 -Q for the Fiscal Period Ended March 31, 2015 Filed May 7 , 2015 Response D ated June 3 , 2015 File No. 1 -35964 Dear Mr. de Talhouët : We have reviewed your response dated June 3 , 2015 and have the following comment . Please respond to this comment within ten busine ss days by providing the requested information or advis e 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 yo ur response. After reviewing your response to this comment , we may have additional comments. Form 10 -Q for the Period Ended March 31, 2015 Management’s Discussion and Analysis of Financial Condition…, page 27 Liquidity and Capital Resources, page 43 We note your response to comment three from our letter dated May 20, 2015. Please address the following: Explain whether or not you consider the transfer of $373.5 million in foreign cash/earnings to the U.S. parent company to be a rep atriation, including the basis for your position; If the transaction was structured, in part, to enable the U.S. parent company to gain access to foreign cash/earnings without accruing U.S. taxes upon repatriation, disclose that fact and quantify the tax savings achieved as a result of using this strategy; and Patrice de Talhouët Coty Inc. July 2 , 2015 Page 2 Explain if the use of this strategy is expected to have a material impact on your unrealized tax benefits as of June 30, 2015 and, if applicable, ensure your financial statement footnotes address the impact. You may contact Lisa Etheredge, Staff Accountant, at (202) 551 -3424 or Anne McConnell, Staff Accountant, at (202) 551 -3709 if you have questions regarding comments on the financial statements and related matters. Please contact Edward M. Kelly, Senior Counsel, at (202) 551 -3728 or Pamela Long, Assistant Director, at (202) 551 -3765 with any other questions. Sincerely, /s/ Pamela Long for John Cash Accounting Branch Chief