SEC Comment Letter for Waste Connections, Inc. (WCN) (CIK 0001318220) (WCN) — May 5, 2010
Waste Connections, Inc. (WCN) (CIK 0001318220)
Date: May 5, 2010 · CIK: 0001318220 · Accession: 0000000000-10-024642
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-164402
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Via U.S. Mail and Facsimile Mail Stop 4631 May 5, 2010 Keith A. Carrigan Vice Chairman and Chief Executive Officer IESI-BFC Ltd. 135 Queens Plate Drive, Suite 300 Toronto, Ontario, Canada M9W6VI Re: IESI-BFC Ltd. Amendment No. 2 to Registrati on Statement on Form F-4 Filed April 19, 2010 File No. 333-164402
Dear Mr. Carrigan:
We have reviewed your filing and have the following comments.
Amendment No. 2 to Form F-4
General
1. Please note the updating requirements of It em 10 of Part 1.B of Form F-4, Item 8.A of Form 20-F and Item 512(4) of Regulation S-K. Please also update to include the interim financial statements for Waste Services, Inc. as well.
2. Please ensure that you supply all information currently omitted from the prospectus prior to requesting acceleration. Financial Statements- IESI-BFC Ltd
Consolidated Balance Sheet, page F-75
3. On page 248, you disclose that all of IES I-BFC’s shares are no par value. Please revise your balance sheet, pro forma financial statements and elsewhere in your filing as applicable, to disclose that y our common stock has no par value.
Keith A. Carrigan IESI-BFC Ltd. May 5, 2010 Page 2 19. Equity
Accumulated Other Comprehensive (loss) income, page F-108
4. Your table on page F-108 indicates th at the amounts presented for foreign currency translations adjustments include reclassifications. Please separately disclose the amounts of your reclassifications adjustments as well as the tax effect on the reclassification adjustments. Refer to ASC 220-10-55 for further guidance. You may contact Ernest Greene, Staf f Accountant at (202) 551-3733 or Lisa Haynes, Senior Accountant at (202) 551-3424 if you have ques tions regarding comments on the financial statements and related ma tters. Please contact Sherry Haywood, Staff Attorney at (202) 551-3345 or me at (202) 551-3760 with any other questions.
S i n c e r e l y , Pamela Long Assistant Director
cc: Joris M. Hogan, Esq. (via facsimile 212/682-0200) Daniel P. Raglan, Esq. Torys LLP 237 Park Avenue New York, New York 10017
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Via U.S. Mail and Facsimile
Mail Stop 4631
May 5, 2010
Keith A. Carrigan Vice Chairman and Chief Executive Officer IESI-BFC Ltd. 135 Queens Plate Drive, Suite 300 Toronto, Ontario, Canada M9W6VI
Re: IESI-BFC Ltd.
Amendment No. 2 to Registrati on Statement on Form F-4
Filed April 19, 2010
File No. 333-164402
Dear Mr. Carrigan:
We have reviewed your filing and have the following comments.
Amendment No. 2 to Form F-4
General
1. Please note the updating requirements of It em 10 of Part 1.B of Form F-4, Item
8.A of Form 20-F and Item 512(4) of Regulation S-K. Please also update to
include the interim financial statements for Waste Services, Inc. as well.
2. Please ensure that you supply all information currently omitted from the prospectus prior to requesting acceleration.
Financial Statements- IESI-BFC Ltd
Consolidated Balance Sheet, page F-75
3. On page 248, you disclose that all of IES I-BFC’s shares are no par value. Please
revise your balance sheet, pro forma financial statements and elsewhere in your filing as applicable, to disclose that y our common stock has no par value.
Keith A. Carrigan
IESI-BFC Ltd. May 5, 2010 Page 2 19. Equity
Accumulated Other Comprehensive (loss) income, page F-108
4. Your table on page F-108 indicates th at the amounts presented for foreign
currency translations adjustments include reclassifications. Please separately
disclose the amounts of your reclassifications adjustments as well as the tax effect
on the reclassification adjustments. Refer to ASC 220-10-55 for further guidance.
You may contact Ernest Greene, Staf f Accountant at (202) 551-3733 or Lisa
Haynes, Senior Accountant at (202) 551-3424 if you have ques tions regarding comments
on the financial statements and related ma tters. Please contact Sherry Haywood, Staff
Attorney at (202) 551-3345 or me at (202) 551-3760 with any other questions.
S i n c e r e l y , Pamela Long
Assistant Director
cc: Joris M. Hogan, Esq. (via facsimile 212/682-0200)
Daniel P. Raglan, Esq.
Torys LLP 237 Park Avenue New York, New York 10017