SEC Company Response from KKR & Co. (KKR) — Apr 26, 2013
KKR & Co. Inc.
Date: April 26, 2013 · CIK: 0001404912 · Accession: 0001104659-13-033669
AI Filing Summary & Sentiment
File numbers found in text: 333-169433, 333-187894
Letter
File No. 333-187894 Laura Crotty Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549-7561
Dear Ms. Crotty,
On behalf of KKR & Co. L.P. (the “Registrant”), we hereby provide the following response to the comment letter, dated April 18, 2013, from the staff of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Staff”) regarding the above-referenced registration statement (the “Registration Statement”). To assist your review, we have retyped the text of the Staff’s comments in italics below. The responses and information described below are based upon information provided to us by the Registrant.
Exhibit Index, page II-1
1. Please file an executed tax opinion that opines to the tax matters for the securities registered on this registration statement rather than the securities registered on Form S-1 (File No. 333-169433) filed on September 16, 2010. Refer to Staff Legal Bulletin No. 19 (October 14, 2011) when preparing your opinion.
In response to the Staff’s comment, the Registrant has filed as Exhibit 8.1 an executed tax opinion that opines to the tax matters for the securities registered on the Registration Statement.
* * * *
BEIJING HONG KONG HOUSTON LONDON LOS ANGELES PALO ALTO SAO PAULO TOKYO WASHINGTON, D.C.
Please do not hesitate to call Joseph H. Kaufman at 212-455-2948 or Arjun Koshal at 212-455-3379 with any questions or further comments you may have regarding this filing or if you wish to discuss the above responses.
Very truly yours,
/s/ Simpson Thacher & Bartlett LLP
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CORRESP 1 filename1.htm SIMPSON THACHER & BARTLETT LLP 425 LEXINGTON AVENUE NEW YORK, N.Y. 10017-3954 (212) 455-2000 FACSIMILE (212) 455-2502 DIRECT DIAL NUMBER E-MAIL ADDRESS April 26, 2013 VIA COURIER AND EDGAR Re: KKR & Co. L.P. Registration Statement on Form S-3 Filed April 12, 2013 File No. 333-187894 Laura Crotty Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549-7561 Dear Ms. Crotty, On behalf of KKR & Co. L.P. (the “Registrant”), we hereby provide the following response to the comment letter, dated April 18, 2013, from the staff of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Staff”) regarding the above-referenced registration statement (the “Registration Statement”). To assist your review, we have retyped the text of the Staff’s comments in italics below. The responses and information described below are based upon information provided to us by the Registrant. Exhibit Index, page II-1 1. Please file an executed tax opinion that opines to the tax matters for the securities registered on this registration statement rather than the securities registered on Form S-1 (File No. 333-169433) filed on September 16, 2010. Refer to Staff Legal Bulletin No. 19 (October 14, 2011) when preparing your opinion. In response to the Staff’s comment, the Registrant has filed as Exhibit 8.1 an executed tax opinion that opines to the tax matters for the securities registered on the Registration Statement. * * * * BEIJING HONG KONG HOUSTON LONDON LOS ANGELES PALO ALTO SAO PAULO TOKYO WASHINGTON, D.C. Please do not hesitate to call Joseph H. Kaufman at 212-455-2948 or Arjun Koshal at 212-455-3379 with any questions or further comments you may have regarding this filing or if you wish to discuss the above responses. Very truly yours, /s/ Simpson Thacher & Bartlett LLP SIMPSON THACHER & BARTLETT LLP cc: Securities and Exhange Commission Eric Envall Suzzane Hayes KKR & Co. L.P. David J. Sorkin 2