SEC Comment Letter for CIMPRESS plc (CMPR) (CIK 0001262976) (CMPR) — Apr 4, 2016
CIMPRESS plc (CMPR) (CIK 0001262976)
Date: April 4, 2016 · CIK: 0001262976 · Accession: 0000000000-16-070843
AI Filing Summary & Sentiment
File numbers found in text: 000-51539
Letter
Mail Stop 3561 April 4, 201 6 Sean E. Quinn Chief Financial Officer Cimpress N.V. Hudsonweg 8 5928 LW Venlo The Netherlands
Re: Cimpress N.V. Form 10-K for the Fiscal Year Ended June 30, 2015 Response dated March 17, 2016 File No. 000-51539
Dear Mr. Quinn :
We have reviewed your March 17, 2016 response to our comment letter 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 10 -K for the Fiscal Year Ended June 30, 2015
Financial Statements
Note 14. Income Taxes, page 82
1. We have reviewed your response to prior comment number 2. Please give consideration to disclosing in your MD&A or financial statement notes , a discussion of the foreign tax jurisdictions that significantly impacted your effective tax rate, including the stat utory rate and the amount of income tax expense related to those jurisdictions for each year presented. Also, where there is significant non -U.S. pre -tax income with no (or an insignificant amount) of income tax expense, please consider disclosing the amo unt of foreign pre -tax income for such countries and the reasons why no income tax expense/(benefit) would be applicable.
Sean E. Quinn Cimpress N.V. April 4, 2016 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the f iling includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Beverly A. Singleton at (202) 551 -3328 or Claire Erlanger at (202) 551 - 3301 if you have questions regarding comments on the financial statements and related matters. Please contact me at ( 202) 551 -3379 with any other questions.
Sincerely,
/s/ Melissa Raminpour
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Mail Stop 3561 April 4, 201 6 Sean E. Quinn Chief Financial Officer Cimpress N.V. Hudsonweg 8 5928 LW Venlo The Netherlands Re: Cimpress N.V. Form 10-K for the Fiscal Year Ended June 30, 2015 Response dated March 17, 2016 File No. 000-51539 Dear Mr. Quinn : We have reviewed your March 17, 2016 response to our comment letter 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 10 -K for the Fiscal Year Ended June 30, 2015 Financial Statements Note 14. Income Taxes, page 82 1. We have reviewed your response to prior comment number 2. Please give consideration to disclosing in your MD&A or financial statement notes , a discussion of the foreign tax jurisdictions that significantly impacted your effective tax rate, including the stat utory rate and the amount of income tax expense related to those jurisdictions for each year presented. Also, where there is significant non -U.S. pre -tax income with no (or an insignificant amount) of income tax expense, please consider disclosing the amo unt of foreign pre -tax income for such countries and the reasons why no income tax expense/(benefit) would be applicable. Sean E. Quinn Cimpress N.V. April 4, 2016 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the f iling includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Beverly A. Singleton at (202) 551 -3328 or Claire Erlanger at (202) 551 - 3301 if you have questions regarding comments on the financial statements and related matters. Please contact me at ( 202) 551 -3379 with any other questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Transportation and Leisure