SEC Comment Letter for Navios Maritime Partners L.P. (NMM) (CIK 0001415921) (NMM) — Mar 8, 2017
Navios Maritime Partners L.P. (NMM) (CIK 0001415921)
Date: March 8, 2017 · CIK: 0001415921 · Accession: 0000000000-17-007695
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-215529
Letter
Mail Stop 3561 March 8, 2017 Angeliki Frangou Chief Executive Officer Navios Maritime Partners L.P. 7 Avenue de Grande Bretagne, Office 11B2 Monte Carlo, MC 98000 Monaco
Re: Navios Maritime Partners L.P. Amendment No. 1 to Registration Statement on Form F-3 Filed March 2 , 2017 File No. 333-215529
Dear Mr. Frangou :
We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information s o we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 27, 2017 letter .
Marshall Islands Tax Consequences, page 72
1. We note your response to our prior comment 2 and reissue in part. We note that the introductory paragraph indicates that this section “is based upon the opinion of Reeder & Simpson P.C. ” We also note that you have filed Reeder & Simpson P.C.’s short -form tax opinion as Exhibit 8.1. Please revise this section to clearly state that the tax consequences are counsel’s opinion. Refer to Secti on III.B.2 of Staff Legal Bulletin No. 19 dated October 14, 2011.
Angeliki Frangou Navios Maritime Partners L.P. March 8, 2017 Page 2
Please contact Donald E. Field at (202) 551 -3680 or me at (202) 551 -3611 with any questions.
Sincerely,
/s/ A.N. Parker
Show Raw Text
Mail Stop 3561 March 8, 2017 Angeliki Frangou Chief Executive Officer Navios Maritime Partners L.P. 7 Avenue de Grande Bretagne, Office 11B2 Monte Carlo, MC 98000 Monaco Re: Navios Maritime Partners L.P. Amendment No. 1 to Registration Statement on Form F-3 Filed March 2 , 2017 File No. 333-215529 Dear Mr. Frangou : We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information s o we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 27, 2017 letter . Marshall Islands Tax Consequences, page 72 1. We note your response to our prior comment 2 and reissue in part. We note that the introductory paragraph indicates that this section “is based upon the opinion of Reeder & Simpson P.C. ” We also note that you have filed Reeder & Simpson P.C.’s short -form tax opinion as Exhibit 8.1. Please revise this section to clearly state that the tax consequences are counsel’s opinion. Refer to Secti on III.B.2 of Staff Legal Bulletin No. 19 dated October 14, 2011. Angeliki Frangou Navios Maritime Partners L.P. March 8, 2017 Page 2 Please contact Donald E. Field at (202) 551 -3680 or me at (202) 551 -3611 with any questions. Sincerely, /s/ A.N. Parker Anne Nguyen Parker Assistant Director Office of Transportation and Leisure cc: Todd E. Mason, Esq. Thompson Hine LLP