SEC Comment Letter for THOMSON REUTERS (TRI) — Jun 27, 2017
THOMSON REUTERS CORP /CAN/ (TRI, TMSOF) (CIK 0001075124)
Date: June 27, 2017 · CIK: 0001075124 · Accession: 0000000000-17-022429
AI Filing Summary & Sentiment
File numbers found in text: 001-31349
Letter
Mail Stop 3561 June 27, 201 7 Deirdre Stanley Executive Vice President , General Counsel and Secretary Thomson Reuters Corporation 333 Bay Street Suite 400 Toronto, Ontario M5H 2R2, Canada
Re: Thomson Reuters Corporation Form 40-F for Fiscal Y ear Ended December 31, 2016 Filed March 9, 201 7 File No. 001-31349
Dear Ms. Stanley :
We have reviewed your filing an d have the following comments. 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.
Form 40 -F for Fiscal Year Ended December 31, 2016
Exhibit 99.1
Notes to Consolidated Financial Statements
Note 22: Deferred Tax, page 133
1. You disclose you did not recognize deferred tax assets of $1,804 million related to $6,471 million of tax losses carried forward. We note this represents essentially all of the total tax losses carried forward at December 31, 2016 of $6,516 million. Of the total amount of tax losses for which no deferred tax assets are recognized, you disclose that $4,884 million is attributed to o ther jurisdictions, the majority of which may be carried forward indefinitely. Please explain to us the basis for your belief it is not probable that tax losses carried forward will be utilized.
Deirdre Stanley Thomson Reuters Corporation June 27, 2017 Page 2
General
2. The document titled “Thomson Reuters Economic Da ta” available on your website identifies the Bank of Sudan, the Central Bank of Syria and the Central Bureau of Statistics, Sudan, as among many Thomson Reuters Economic Data Sources. Please clarify for us whether you source economic data directly from th e Sudanese and Syrian entities you identify, or indirectly. If you source the data indirectly, please tell us whether you source the data through third -party sources not located in or affiliated with Sudan or Syria. We may have further comment.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
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
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Mail Stop 3561 June 27, 201 7 Deirdre Stanley Executive Vice President , General Counsel and Secretary Thomson Reuters Corporation 333 Bay Street Suite 400 Toronto, Ontario M5H 2R2, Canada Re: Thomson Reuters Corporation Form 40-F for Fiscal Y ear Ended December 31, 2016 Filed March 9, 201 7 File No. 001-31349 Dear Ms. Stanley : We have reviewed your filing an d have the following comments. 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. Form 40 -F for Fiscal Year Ended December 31, 2016 Exhibit 99.1 Notes to Consolidated Financial Statements Note 22: Deferred Tax, page 133 1. You disclose you did not recognize deferred tax assets of $1,804 million related to $6,471 million of tax losses carried forward. We note this represents essentially all of the total tax losses carried forward at December 31, 2016 of $6,516 million. Of the total amount of tax losses for which no deferred tax assets are recognized, you disclose that $4,884 million is attributed to o ther jurisdictions, the majority of which may be carried forward indefinitely. Please explain to us the basis for your belief it is not probable that tax losses carried forward will be utilized. Deirdre Stanley Thomson Reuters Corporation June 27, 2017 Page 2 General 2. The document titled “Thomson Reuters Economic Da ta” available on your website identifies the Bank of Sudan, the Central Bank of Syria and the Central Bureau of Statistics, Sudan, as among many Thomson Reuters Economic Data Sources. Please clarify for us whether you source economic data directly from th e Sudanese and Syrian entities you identify, or indirectly. If you source the data indirectly, please tell us whether you source the data through third -party sources not located in or affiliated with Sudan or Syria. We may have further comment. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. 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 Office of Transportation and Leisure