SEC Comment Letter for Capri Holdings Ltd (CPRI) (CIK 0001530721) (CPRI) — Aug 30, 2017
Capri Holdings Ltd (CPRI) (CIK 0001530721)
Date: Aug. 30, 2017 · CIK: 0001530721 · Accession: 0000000000-17-030729
AI Filing Summary & Sentiment
File numbers found in text: 001-35368
Letter
Mail Stop 3561 August 30 , 2017 Via E -mail Thomas J. Edwards, Jr. Chief Financial Officer Michael Kors Holdings Limited 33 Kingsway London, United Kingdom WC2B 6UF
Re: Michael Kors Holdings Limited Form 10-K for the Fiscal Y ear Ended April 1, 2017 Filed May 31, 2017 File No. 001-35368
Dear Mr . Edwards :
We have reviewed your filing 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 respond to these comments within ten business days by prov iding the requested information or adv ise us as soon as possible when you will respond . If you do not believe our comments appl y to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments , we may have additional comments .
Form 10-K for the Fiscal Year Ended April 1, 2017 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Comparison of Fiscal 2017 with Fiscal 2016 Provision for Income Taxes, page 39
1. You have attributed a lower effective tax rate for Fiscal 2017 to t he favorable effect of global financing activities. Please expand your discussion to describe the nature of these global financing activities and provide reasons for the significant impact that these activities had on your income tax rate.
Thomas J. Edwards, Jr. Michael Kors Holdings Limited August 30 , 2017 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Steve Lo at (202) 551 -3394 or Suying Li at (202) 551-3335 if you have questions regarding these comments.
Sincerely,
/s/Craig Arakawa
Show Raw Text
Mail Stop 3561
August 30 , 2017
Via E -mail
Thomas J. Edwards, Jr.
Chief Financial Officer
Michael Kors Holdings Limited
33 Kingsway
London, United Kingdom
WC2B 6UF
Re: Michael Kors Holdings Limited
Form 10-K for the Fiscal Y ear Ended April 1, 2017
Filed May 31, 2017
File No. 001-35368
Dear Mr . Edwards :
We have reviewed your filing 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 respond to these comments within ten business days by prov iding the requested
information or adv ise us as soon as possible when you will respond . If you do not believe our
comments appl y to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments , we may have additional comments .
Form 10-K for the Fiscal Year Ended April 1, 2017
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Comparison of Fiscal 2017 with Fiscal 2016
Provision for Income Taxes, page 39
1. You have attributed a lower effective tax rate for Fiscal 2017 to t he favorable effect of
global financing activities. Please expand your discussion to describe the nature of these
global financing activities and provide reasons for the significant impact that these
activities had on your income tax rate.
Thomas J. Edwards, Jr.
Michael Kors Holdings Limited
August 30 , 2017
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Steve Lo at (202) 551 -3394 or Suying Li at (202) 551-3335 if you have
questions regarding these comments.
Sincerely,
/s/Craig Arakawa
Craig Arakawa
Accounting Branch Chief
Office of Beverages, Apparel and
Mining