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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

AI Filing Summary & Sentiment

File numbers found in text: 001-31349

Date
December 31, 2014
Author
/s/ Lyn Shenk
Form
UPLOAD
Company
THOMSON REUTERS CORP /CAN/ (TRI, TMSOF) (CIK 0001075124)

Letter

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

Show Raw Text
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