SEC Comment Letter for ACCENTURE SCA (CIK 0001143908) — Jun 17, 2005
ACCENTURE SCA (CIK 0001143908)
Date: June 17, 2005 · CIK: 0001143908 · Accession: 0000000000-05-030809
AI Filing Summary & Sentiment
Referenced dates: April 21, 2005
Letter
Mail Stop 04-09 June 17, 2005 Mr. Douglas G. Scrivner, General Counsel and Secretary Accenture Ltd Canon`s Court 22 Victoria Street Hamilton HM 12 Bermuda
RE: Accenture SCA File No. 0-49713 Form 10-K for the year ended August 31, 2004
Dear Mr. Scrivner:
We have read your letter dated April 21, 2005 and have the following comment.
Form 10-K
Note 2 - Restructuring and Organization Costs (Benefits), page F- 1. We note your response to our previous comment no. 3. With regards to the 2001 restructuring liability, please provide the following: * Please provide a reconciliation of the accrued liability for reorganization costs at the end of each fiscal year, beginning with the $544 million accrued in fiscal 2001 for indirect taxes and other costs imposed on transfers of assets to a corporate structure, and ending with the $454 million accrual outstanding at August 31, 2004. * Has the Company paid out any amounts against these liabilities or has the reductions to the liability account been mainly through benefits recognized in income resulting from final determinations? * Tell us what the "final determinations" entail. What is involved in the determining the final settlement amounts and why do you anticipate this taking seven years, to 2008? * Tell us what you mean by "certain shareholder and partners expenses related to transfer of certain entities to Accenture as part of the reorganization". What type of expenses are you referring to? How and when do you intend on paying these expenses?
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please file your response on EDGAR. If you have any questions, you may contact Jorge L. Bonilla at (202) 551-3414 or me at (202) 551-3499.
Sincerely,
Kathleen A. Collins
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 04-09
June 17, 2005
Mr. Douglas G. Scrivner, General Counsel and Secretary
Accenture Ltd
Canon`s Court
22 Victoria Street
Hamilton HM 12 Bermuda
RE: Accenture SCA
File No. 0-49713
Form 10-K for the year ended August 31, 2004
Dear Mr. Scrivner:
We have read your letter dated April 21, 2005 and have the
following comment.
Form 10-K
Note 2 - Restructuring and Organization Costs (Benefits), page F-
19
1. We note your response to our previous comment no. 3. With
regards
to the 2001 restructuring liability, please provide the following:
* Please provide a reconciliation of the accrued liability for
reorganization costs at the end of each fiscal year, beginning
with
the $544 million accrued in fiscal 2001 for indirect taxes and
other
costs imposed on transfers of assets to a corporate structure, and
ending with the $454 million accrual outstanding at August 31,
2004.
* Has the Company paid out any amounts against these liabilities
or
has the reductions to the liability account been mainly through
benefits recognized in income resulting from final determinations?
* Tell us what the "final determinations" entail. What is
involved
in the determining the final settlement amounts and why do you
anticipate this taking seven years, to 2008?
* Tell us what you mean by "certain shareholder and partners
expenses
related to transfer of certain entities to Accenture as part of
the
reorganization". What type of expenses are you referring to? How
and when do you intend on paying these expenses?
Please respond to this comment within 10 business days or
tell
us when you will provide us with a response. Please file your
response on EDGAR. If you have any questions, you may contact
Jorge
L. Bonilla at (202) 551-3414 or me at (202) 551-3499.
Sincerely,
Kathleen A. Collins
Branch Chief
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Accenture SCA
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