SEC Comment Letter for Live Nation Entertainment, Inc. (LYV) (CIK 0001335258) (LYV) — May 17, 2012
Live Nation Entertainment, Inc. (LYV) (CIK 0001335258)
Date: May 17, 2012 · CIK: 0001335258 · Accession: 0000000000-12-025698
AI Filing Summary & Sentiment
File numbers found in text: 001-32601
Referenced dates: May 7, 2012
Letter
May 17, 2012 Via E-Mail Ms. Kathy Willard Chief Financial Officer Live Nation Entertainment, Inc. 9348 Civic Center Drive Beverly Hills, California 90210 Re: Live Nation Entertainment, Inc. Form 10-K for the Year Ended December 31, 2011 Filed February 24, 2012 File No. 001-32601
Dear Ms. Willard: We have reviewed your response letter dated May 7, 2012 and have the following comment. In our comment, we may ask you to pr ovide us with information so we may better understand your disclosure. Please respond to this letter within 10 bus iness days by confirming that you will revise your document in future filings and providing an y requested information. If you do not believe our comments apply to your facts and circumst ances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2011
Management’s Discussion & Analysis
Critical Accounting Policies and Estimates, page 73 Income Taxes, page 76
1. We note from your response to our prior comment the countries that comprise 95% of the reconciling item labeled “differences of forei gn taxes from U.S. statutory rates” within the rate reconciliation table in Note 10 are Luxembourg, Ireland, the United Kingdom and the Netherlands. In light of the fact it appears you have derive d a substantial amount of profit in a country that is considered a tax haven (Ireland), we believe you should revise your discussion to disclose these countri es in which you have generated substantial profit with very low tax rates. We believe th at this disclosure is consistent with the objectives in the guidance in Item 303(a)(3 )(i) of Regulation S-K. Please revise accordingly.
Ms. Kathy Willard Live Nation Entertainment, Inc. May 17, 2012 Page 2
You may contact Claire Erla nger at (202) 551-3301 or Jean Yu at (202) 551-3305 if you have questions regarding comments on the financ ial statements and related matters. You may also contact me at (202) 551-3813. Sincerely, /s/ Linda Cvrkel Linda Cvrkel Branch Chief
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May 17, 2012 Via E-Mail Ms. Kathy Willard Chief Financial Officer Live Nation Entertainment, Inc. 9348 Civic Center Drive Beverly Hills, California 90210 Re: Live Nation Entertainment, Inc. Form 10-K for the Year Ended December 31, 2011 Filed February 24, 2012 File No. 001-32601 Dear Ms. Willard: We have reviewed your response letter dated May 7, 2012 and have the following comment. In our comment, we may ask you to pr ovide us with information so we may better understand your disclosure. Please respond to this letter within 10 bus iness days by confirming that you will revise your document in future filings and providing an y requested information. If you do not believe our comments apply to your facts and circumst ances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31, 2011 Management’s Discussion & Analysis Critical Accounting Policies and Estimates, page 73 Income Taxes, page 76 1. We note from your response to our prior comment the countries that comprise 95% of the reconciling item labeled “differences of forei gn taxes from U.S. statutory rates” within the rate reconciliation table in Note 10 are Luxembourg, Ireland, the United Kingdom and the Netherlands. In light of the fact it appears you have derive d a substantial amount of profit in a country that is considered a tax haven (Ireland), we believe you should revise your discussion to disclose these countri es in which you have generated substantial profit with very low tax rates. We believe th at this disclosure is consistent with the objectives in the guidance in Item 303(a)(3 )(i) of Regulation S-K. Please revise accordingly. Ms. Kathy Willard Live Nation Entertainment, Inc. May 17, 2012 Page 2 You may contact Claire Erla nger at (202) 551-3301 or Jean Yu at (202) 551-3305 if you have questions regarding comments on the financ ial statements and related matters. You may also contact me at (202) 551-3813. Sincerely, /s/ Linda Cvrkel Linda Cvrkel Branch Chief