SEC Comment Letter for CIT GROUP INC (CIK 0001171825) — Mar 4, 2020
CIT GROUP INC (CIK 0001171825)
Date: March 4, 2020 · CIK: 0001171825 · Accession: 0000000000-20-002000
AI Filing Summary & Sentiment
File numbers found in text: 001-31369
Show Raw Text
March 4, 2020
John Fawcett
Chief Financial Officer
CIT Group Inc.
11 West 42nd Street
New York, New York 10036
Re:CIT Group Inc.
Form 10-K for Fiscal Year Ended December 31, 2019
Filed February 20, 2020
File No. 001-31369
Dear Mr. Fawcett:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to our comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Income Taxes, page 52
1.Please provide us an accounting analysis supporting the reversal of the deferred tax
liability and related $53.2 million tax benefit in 2019 related to the change in indefinite
reinvestment tax assertion for unremitted earnings from Canada. Specifically tell us how
you considered the mandatory deemed repatriation of post-1986 undistributed Non-U.S.
earnings and profits from the 2017 Tax Cuts and Jobs Act.
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.
FirstName LastNameJohn Fawcett
Comapany NameCIT Group Inc.
March 4, 2020 Page 2
FirstName LastName
John Fawcett
CIT Group Inc.
March 4, 2020
Page 2
You may contact John Spitz, Staff Accountant, at (202) 551-3484 or Michael Volley,
Staff Accountant, at (202) 551-3437 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance