SEC Comment Letter for TRANSALTA CORP (TAC, TACPF, TSLTF) (CIK 0001144800) (TAC) — Jul 27, 2005
TRANSALTA CORP (TAC, TACPF, TSLTF) (CIK 0001144800)
Date: July 27, 2005 · CIK: 0001144800 · Accession: 0000000000-05-038658
AI Filing Summary & Sentiment
Referenced dates: July 5, 2005, July 25, 2005
Letter
July 27, 2005 By Facsimile and U.S. Mail Mr. Ian Bourne Chief Financial Officer TransAlta Corp 110-12th Avenue SW PO Box 1900 Station M Calgary, AB T2P 2M1
Re: TransAlta Corporation Form 40-F for the year ended December 31, 2004 Filed April 1, 2005 File No. 1-15214
Dear Mr. Bourne:
We reviewed your responses to our prior comments on the above referenced filings as set forth in your letter dated July 25, 2005. Our review resulted in the following accounting comment.
Form 40-F for Fiscal Year Ended December 31, 2004
1. We note your response to comment two of our letter dated July 5, 2005. It appears that EITF 88-18 is not applicable to the accounting for the sale of three facilities to TA Cogen with respect to the initial public offering of TA Power. EITF 88-18 addresses sales of future revenues or income. The accounting for your transaction appears to be more appropriately addressed in question two of SAB Topic 5:H. Please quantify for us the amounts recognized in earnings under US GAAP for the periods in question (1998 through July 2003), and if material, please amend the US GAAP reconciliation note to your financial statements included as part of your 2004 Form 40-F to eliminate prior gains which were amortized into income up until the time when the buyback provision was eliminated. Please explain to us if your external auditors still support the accounting for this transaction from a US GAAP perspective. We may have further comment.
``` ```````````````````````````````````````````````As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please provide us with a response letter that keys your response to our comment and provides any requested supplemental information. Please file your response letter on EDGAR as a correspondence file.
If you have any questions regarding this comment, please direct them to Robert Babula, Staff Accountant, at (202) 551-3339 or, in his absence, to the undersigned at (202) 551-3841. Any other questions regarding disclosures issues may be directed to H. Christopher Owings, Assistant Director at (202) 551-3725.
Sincerely,
Michael Moran, Esq.
Branch Chief
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> Mail Stop 3561 July 27, 2005 By Facsimile and U.S. Mail Mr. Ian Bourne Chief Financial Officer TransAlta Corp 110-12th Avenue SW PO Box 1900 Station M Calgary, AB T2P 2M1 Re: TransAlta Corporation Form 40-F for the year ended December 31, 2004 Filed April 1, 2005 File No. 1-15214 Dear Mr. Bourne: We reviewed your responses to our prior comments on the above referenced filings as set forth in your letter dated July 25, 2005. Our review resulted in the following accounting comment. Form 40-F for Fiscal Year Ended December 31, 2004 1. We note your response to comment two of our letter dated July 5, 2005. It appears that EITF 88-18 is not applicable to the accounting for the sale of three facilities to TA Cogen with respect to the initial public offering of TA Power. EITF 88-18 addresses sales of future revenues or income. The accounting for your transaction appears to be more appropriately addressed in question two of SAB Topic 5:H. Please quantify for us the amounts recognized in earnings under US GAAP for the periods in question (1998 through July 2003), and if material, please amend the US GAAP reconciliation note to your financial statements included as part of your 2004 Form 40-F to eliminate prior gains which were amortized into income up until the time when the buyback provision was eliminated. Please explain to us if your external auditors still support the accounting for this transaction from a US GAAP perspective. We may have further comment. ``` ```````````````````````````````````````````````As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please provide us with a response letter that keys your response to our comment and provides any requested supplemental information. Please file your response letter on EDGAR as a correspondence file. If you have any questions regarding this comment, please direct them to Robert Babula, Staff Accountant, at (202) 551-3339 or, in his absence, to the undersigned at (202) 551-3841. Any other questions regarding disclosures issues may be directed to H. Christopher Owings, Assistant Director at (202) 551-3725. Sincerely, Michael Moran, Esq. Branch Chief `` ?? ?? ?? ?? Mr. Ian Bourne TransAlta Corp July 27, 2005 Page 2 </TEXT> </DOCUMENT>