SecProbe.io

July 26, 2019
Sean Douglas
Chief Financial Officer
Huntsman CORP
Huntsman International LLC
10003 Woodloch Forest Driv
The Woodlands, Texas 77380
Re:Huntsman CORP
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed: February 12, 2019
Form 10-Q for the Quarterly Period Ended March 31, 2018
Filed: April 30, 2019
File No. 001-32427
Huntsman International LLC
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed: February 12, 2019
Form 10-Q for the Quarterly Period Ended March 31, 2018
Filed: April 30, 2019
File No. 333-85141
Dear Mr. Douglas:
            We have reviewed your filing 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 December 31, 2018
Note 4. Discontinued Operations and Business Disposition, page F-27
1.We note that notwithstanding your remaining 49% interest in Venator, you continue to
reflect this business as discontinued operations.  Please tell us how you considered the

 FirstName LastNameSean Douglas
 Comapany NameHuntsman CORP
 July 26, 2019 Page 2
 FirstName LastName
Sean Douglas
Huntsman CORP
July 26, 2019
Page 2
nature, time frame and extent of this continuing involvement in Venator in your
determination that the disposition of your 51% interest resulted in a strategic shift that has
had (or will have) a major effect on your results of operations and financial results such
that this disposition qualified for discontinued operations presentation.  Refer to ASC 205-
20-45-1B.  Please ensure your response addresses any changes to your plans subsequent to
Venator’s IPO and address the guidance in ASC 205-20-45-1E.f.  Also, explain the extent
of your involvement in Venator’s operations subsequent to it's IPO and subsequent to
your deconsolidation.  Finally, address your intentions with regard to the time frame of
your continued involvement and explain how you contemplated the guidance in ASC 205-
20-45-1E.e.  In this regard, we note from your earnings calls that the determination to sell
your remaining interest is dependent on the future stock price of Venator.

Form 10-Q for the Quarterly Period Ended March 31, 2019
Note 4. Discontinued Operations and Business Dispositions, page 20
2.We note that the $75 million fair value adjustment to your investment in Venator appears
material to your results of operations.  Please tell us what consideration was given to
providing the disclosures required by Rule 4-08(g) of Regulation S-X for this investment.
 In this regard, we believe that the income test set forth in Rule 1-02(w) should be
computed using as the numerator the change in the fair value reflected in your income
statement rather than the equity in earnings of the investee.
            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 Tracey McKoy, Staff Accountant, at (202)551-3772 or Jeanne Baker,
Assistance Chief Account, at (202) 551-3691 or Terence O'Brien, Accounting Branch Chief,  at
(202) 551-3355 if you have questions regarding comments on the financial statements and
related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction