SEC Comment Letter for QUANTA SERVICES, INC. (PWR) (CIK 0001050915) (PWR) — Jun 27, 2016
QUANTA SERVICES, INC. (PWR) (CIK 0001050915)
Date: June 27, 2016 · CIK: 0001050915 · Accession: 0000000000-16-082060
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Mail Stop 4631 June 27, 2016 Via E -mail Mr. Derrick A. Jensen, Chief Financial Officer Quanta Services, Inc. 2800 Post Oak Boulevard, Suite 2600 Houston, TX 77056 Re: Quanta Services, Inc. Form 10-K for the year ended December 31, 2015 Filed February 29, 2016 File No. 1 -13831 Dear Mr. Jensen : We have reviewed your May 26, 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 respond. 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 com ments in our April 28, 2016 letter . Form 10 -K for the year ended December 31, 2015 Consolidated Financial Statements 2. Summary of Significant Accounting Policies, Revenue Recognition, page 98 1. We note your response to prior comment 4 from our let ter dated April 28, 2016. To the extent that material positive and negative changes in estimates offset each other in a period, please revise future filings to separately quan tify and disclose their impact. In addition, we note in MD&A you attribute decl ines in gross profit margins during the year ended December 31, 2015 to $73 million in contract losses you recorded during the period; however, we note no disclosures that indicate the contract losses were offset by positive changes in estimates on other c ontracts that you r ecorded during the same period. Mr. Derrick A. Jensen Quanta Services, Inc. June 27, 2016 Page 2 Please revise MD&A in future filings to separately disclose and discuss the impact of material positive and negative changes in estimates during each period presented. Form 8 -K filed on May 5, 2016 2. It appears to us you may not adequately explain why each non -GAAP financial measure you present is useful to investors and may not explain or properly present the tax effects of adjustments to your non -GAAP financial measures which may be inconsistent with the updated Compliance and Disclosure Interpre tations issued on May 17, 2016. Please review this guidance when preparing your next earnings release. You may contact Mindy Hooker at (202) 551 -3732, Anne McConnell at (202) 551 -3709 or me at (202) 551 -3768 wi th any questions. Sincerely, /s/ John Cash John Cash Branch Chief Office of Manufacturing and Construction