SEC Comment Letter for TELEMIG CELULAR PARTICIPACOES SA (CIK 0001066118) — Oct 27, 2005
TELEMIG CELULAR PARTICIPACOES SA (CIK 0001066118)
Date: Oct. 27, 2005 · CIK: 0001066118 · Accession: 0000000000-05-054626
AI Filing Summary & Sentiment
Referenced dates: August 17, 2005, July 26, 2005
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Mail Stop 3561
October 25, 2005
Mr. Antonio Jose Ribeiro dos Santos
Chief Executive Officer
Telemig Celular Participacoes S.A.
SCN Quadra 4, Bloco B, Ed. Centro Empresarial Varig, Torre Oeste,
Sala 702-A
70714-000 Brasilia-DF, Brazil
Re: Telemig Celular Participacoes S.A.
Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 30, 2005
File No. 1-14483
Dear Mr. Santos:
We have reviewed your supplemental response letter dated
August
17, 2005 as well as your filing and have the following comments.
As
noted in our comment letter dated July 26, 2005, we have limited
our
review to your financial statements and related disclosures and do
not intend to expand our review to other portions of your
documents.
Form 20-F for Fiscal Year Ended December 31, 2004
Consolidated Statements of Operations and Comprehensive Income,
page
F-6
1. We note your response to prior comment 4. Please describe the
ICMS, PIS and COFINS taxes for us in more detail and address the
following items:
* Tell us what you mean by your statement that "taxes paid on
allowable inputs are offset against taxes determined upon sale to
the
Company`s customers."
* Describe your obligations with respect to these taxes. Tell us
whether you are responsible for paying the taxes to the taxing
authorities, regardless of whether you are able to collect the
taxes
from your customer.
* Are you required to pass these taxes on to your customers?
* Describe for us in more detail how you determined that you are
not
the primary obligor with respect to these taxes.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. You may contact
Melissa Hauber, Staff Accountant, at (202) 551-3368 or Carlos
Pacho,
Senior Assistant Chief Accountant, at (202) 551-3835 if you have
questions regarding comments on the financial statements and
related
matters. Please contact me at (202) 551-3810 with any other
questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Antonio Jose Ribeiro dos Santos
Telemig Celular Participacoes S.A.
October 25, 2005
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