SEC Comment Letter for THOMSON REUTERS (TRI) — Jul 10, 2015
THOMSON REUTERS CORP /CAN/ (TRI, TMSOF) (CIK 0001075124)
Date: July 10, 2015 · CIK: 0001075124 · Accession: 0000000000-15-036250
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File numbers found in text: 001-31349
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July 10 , 201 5 Stephane Bello Executive Vice President Finance and Chief Financial Officer Thomson Reuters Corporation 3 Times Square New York , NY 10036 Re: Thomson Reuters Corporation Form 40-F for Fiscal Y ear Ended December 31, 2014 Filed March 13, 201 5 File No. 001-31349 Dear Mr. Bello : We have reviewed your filing an d have the following comment. Our comment asks you to provide us with information so we may better understand your disclosure s. Please respond to this letter within ten business days by providing the requested information. If you do not believe our comment appl ies to your facts and circumstances, pl ease tell us why in your response. After reviewing the information you provide in response to these comment s, we may have additional comments. Exhibit 99.1 Notes to Consolidated Financial Statements Note 6: Other operating gains, net, pa ge 96 1. You disclose that you recorded in 2014 a $931 million gain related to the release of accumulated foreign currency translation adjustments from shareholders’ equity that was triggered by the loss of control of a subsidiary. So that we may better und erstand your accounting for this transaction, please tell us the following: The name of the subsidiary for which control was lost; The location of the subsidiary; The nature of the subsidiary’s operations; The form of control before the transaction; The f orm of control you retained and the subsequent accounting for your investment going forward; Stephane Bello Thomson Reuters Corporation July 10 , 2015 Page 2 Explain how you lost control of the subsidiary through the permanent settlement of an intercompany loan, an apparent related party transaction, and the facts and c ircumstances leading to the settlement; Cite the accounting literature you relied upon to support your accounting; and Provide the calculation on how you computed the gain. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the compa ny 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 responding to our comments, please provide a written statement from the co mpany acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; 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. You may contact Patrick Kuhn at (202) 551 -3308 or Doug Jones at (202) 551 -3309 with any questions . You may also call me at (202) 551 -3380. Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief