SEC Comment Letter for Live Nation Entertainment, Inc. (LYV) (CIK 0001335258) (LYV) — Jul 31, 2015
Live Nation Entertainment, Inc. (LYV) (CIK 0001335258)
Date: July 31, 2015 · CIK: 0001335258 · Accession: 0000000000-15-039557
AI Filing Summary & Sentiment
Letter
July 31 , 2015 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, 2014 Response Dated June 30 , 2015 File No. 001 -32601
Dear Ms. Willard :
We have reviewed your June 30 , 2015 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 r espond 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. Unless we note otherwise, our references to prior comments are to comments in our June 16 , 2015 letter .
Form 10 -K for the Year Ended December 31, 2014
Note 9. Income Taxes, page 83
1. We note your response to our prior comments and have no further questions related to how you calculated the reconciling items in your income tax rate reconciliation. However, please tell us your consideration of disclosing the following information to further clarify the difference between income tax computed at the United States federal statutory rate and income tax computed at the effective tax rate: The concentration of pre -tax income in Luxembourg, as well as the foreign statutory rate and foreign effective tax rate in Luxembourg; The nondeductible goodwill impairment charge was recorded in the United Kingdom, and; The nature of “Non -United States i ncome inclusions and exclusions” in periods where this adjustment is material.
Kathy Willard Live Nation Entertainment, Inc. July 31 , 2015 Page 2
You may contact Claire Erlanger at (202) 551 -3301 or me at (202) 551 -3379 with any questions.
Sincerely,
/s/ Melissa Raminpour
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July 31 , 2015 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, 2014 Response Dated June 30 , 2015 File No. 001 -32601 Dear Ms. Willard : We have reviewed your June 30 , 2015 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 r espond 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. Unless we note otherwise, our references to prior comments are to comments in our June 16 , 2015 letter . Form 10 -K for the Year Ended December 31, 2014 Note 9. Income Taxes, page 83 1. We note your response to our prior comments and have no further questions related to how you calculated the reconciling items in your income tax rate reconciliation. However, please tell us your consideration of disclosing the following information to further clarify the difference between income tax computed at the United States federal statutory rate and income tax computed at the effective tax rate: The concentration of pre -tax income in Luxembourg, as well as the foreign statutory rate and foreign effective tax rate in Luxembourg; The nondeductible goodwill impairment charge was recorded in the United Kingdom, and; The nature of “Non -United States i ncome inclusions and exclusions” in periods where this adjustment is material. Kathy Willard Live Nation Entertainment, Inc. July 31 , 2015 Page 2 You may contact Claire Erlanger at (202) 551 -3301 or me at (202) 551 -3379 with any questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief