SecProbe.io

March 22, 2019
Matthew Marsh
Chief Financial Officer
James Hardie Industries plc
Europa House, Second Floor, Harcourt Centre
Harcourt Street, Dublin 2, Ireland
Re:James Hardie Industries plc
Form 20-F for the Year Ended March 31, 2018
Filed May 22, 2018
File No. 001-15240
Dear Mr. Marsh:
            We have limited our review of your filing to the financial statements and related
disclosures and 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 business days by providing the requested
information or advise 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 20-F for the Year Ended March 31, 2018
Consolidated Financial Statements
14. Income Taxes, page 145
1.We note your disclosures related to the adoption of ASU 2016-16.  Please more fully
address the following:
•Clarify the nature of the internal restructuring you undertook to align certain intangible
assets;
•Disclose how you determined the amount of the related tax valuation allowance you
recorded; and
•To the extent your realization of net deferred tax assets is subject to material
assumptions and estimates, revise your critical accounting policies to disclose and
discuss the assumptions and estimates, including, if applicable, the jurisdictions to
which they relate.

 FirstName LastNameMatthew Marsh
 Comapany NameJames Hardie Industries plc
 March 22, 2019 Page 2
 FirstName LastName
Matthew Marsh
James Hardie Industries plc
March 22, 2019
Page 2
17. Operating Segment Information and Concentration of Risk, page 153
2.Please revise your geographic disclosures to present net sales and identifiable assets
related to the U.S. as required by ASC 280-10-50-41.  To the extent that substantially all
the amounts disclosed for North America relate to the U.S., please clarify that fact.
            In closing, 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 Ernest Greene, Staff Accountant at 202-551-3733 or Anne McConnell,
Staff Accountant at 202-551-3709 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction