SEC Comment Letter for Restaurant Brands International Inc. (QSR) (CIK 0001618756) (QSR) — Jul 19, 2016
Restaurant Brands International Inc. (QSR) (CIK 0001618756)
Date: July 19, 2016 · CIK: 0001618756 · Accession: 0000000000-16-084897
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 July 19, 2016 Joshua Kobza Chief Financial Officer Restaurant Brands International, Inc. 226 Wyecroft Road Oakville, Ontario Canada L6K 3X7
Re: Restaurant Brands International, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed February 26, 2016 File No. 001 -36786
Dear Mr. Kobza :
We have reviewed your June 28, 2016 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to the comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment , we may have additional comments.
Form 8 -K furnished April 28, 2016
1. We not e that your earnings release furnished on Form 8 -K includes the prominent disclosure of certain non -GAAP financial measures such as adjusted diluted EPS and adjusted EBITDA in the Highlights section at the top of the press release, which is inconsistent wi th the updated Compliance and Disclosure Interpretations issued on May 17, 2016. Please review this guidance when preparing your next earnings release.
Joshua Kobza Restaurant Brands International, Inc. July 19, 2016 Page 2
You may contact Krist in Shifflett at 202 -551-3381, Claire Erlanger at 202 -551-3301 or me at 202 -551-3377 with any questions.
Sincerely,
/s/ Andrew Mew
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Mail Stop 3561 July 19, 2016 Joshua Kobza Chief Financial Officer Restaurant Brands International, Inc. 226 Wyecroft Road Oakville, Ontario Canada L6K 3X7 Re: Restaurant Brands International, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed February 26, 2016 File No. 001 -36786 Dear Mr. Kobza : We have reviewed your June 28, 2016 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment apply to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment , we may have additional comments. Form 8 -K furnished April 28, 2016 1. We not e that your earnings release furnished on Form 8 -K includes the prominent disclosure of certain non -GAAP financial measures such as adjusted diluted EPS and adjusted EBITDA in the Highlights section at the top of the press release, which is inconsistent wi th the updated Compliance and Disclosure Interpretations issued on May 17, 2016. Please review this guidance when preparing your next earnings release. Joshua Kobza Restaurant Brands International, Inc. July 19, 2016 Page 2 You may contact Krist in Shifflett at 202 -551-3381, Claire Erlanger at 202 -551-3301 or me at 202 -551-3377 with any questions. Sincerely, /s/ Andrew Mew Andrew Mew Senior Assistant Chief Accountant Office of Transportation and Leisure