SEC Comment Letter 0000000000-24-012584 to Medtronic plc (MDT) (CIK 0001613103)
Medtronic plc (MDT) (CIK 0001613103)
Date: Nov. 13, 2024 · CIK: 0001613103 · Accession: 0000000000-24-012584
AI Filing Summary & Sentiment
File numbers found in text: 001-36820
Letter
November 13, 2024 Jennifer Kirk Senior Vice President, Global Controller and Chief Accounting Officer Medtronic plc Building Two, Parkmore Business Park West Galway, Ireland Re:Medtronic plc Form 10-K for Fiscal Year Ended April 26, 2024 Filed June 20, 2024 File No. 001-36820 Dear Jennifer Kirk: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended April 26, 2024 Item 7. Management's Discussion and Analysis of Financial Condition and Result of Operations Income Taxes, page 41 1.Please provide us additional quantitative and qualitative information regarding the potential impact from enacted Pillar Two legislation. For example, please describe in further detail the impact from enacted legislation in Ireland. In closing, 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.
November 13, 2024 Page 2 Please contact Michael Fay at 202-551-3812 or Li Xiao at 202-551-4391 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
Show Raw Text
November 13, 2024
Jennifer Kirk
Senior Vice President, Global Controller and Chief Accounting Officer
Medtronic plc
Building Two, Parkmore Business Park West
Galway, Ireland
Re:Medtronic plc
Form 10-K for Fiscal Year Ended April 26, 2024
Filed June 20, 2024
File No. 001-36820
Dear Jennifer Kirk:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended April 26, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Result of
Operations
Income Taxes, page 41
1.Please provide us additional quantitative and qualitative information regarding the
potential impact from enacted Pillar Two legislation. For example, please describe in
further detail the impact from enacted legislation in Ireland.
In closing, 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.
November 13, 2024
Page 2
Please contact Michael Fay at 202-551-3812 or Li Xiao at 202-551-4391 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services