Explorer

The firm selected for testing a control that consisted of a review of uncertain tax positions. The firm did not evaluate the review procedures that the control owner performed including the criteria the control owner used to identify items for follow up and whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the review of the provision for income taxes including the issuer's review of (1) the effective tax rate reconciliation and (2) considerations regarding the need to record a deferred tax asset valuation allowance. The firm did not evaluate the specific review procedures that the control owner performed to assess the effective tax rate and whether a valuation allowance was needed. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the issuer's quarterly review of the provision for income taxes. The firm did not evaluate the review procedures that the control owner performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing certain controls that consisted of the issuer's review of the income tax provision transfer-pricing reserves uncertain tax positions and tax disclosures. The firm did not evaluate the review procedures that the control owner performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the issuer's review of the provision for income taxes including the valuation of deferred tax assets. The firm did not evaluate the specific review procedures that the control owner performed to evaluate the reasonableness of the valuation of deferred tax assets. (AS 2201.42 and .44) Unrelated to our review the issuer reevaluated its accounting for the income tax provision and concluded that a material misstatement existed that had not been previously identified. The issuer subsequently restated its financial statements to correct this and other material misstatements and the firm revised and reissued its report on the financial statements. The issuer also reevaluated its controls over the income tax provision and concluded that a material weakness existed that had not been previously identified. The issuer subsequently revised its report on ICFR to reflect this material weakness and the other material weaknesses discussed herein and the firm modified its opinion on the effectiveness of the issuer's ICFR to express an adverse opinion and reissued its report.

The firm selected for testing controls that consisted of management's review of income tax provisions and tax returns. The firm did not evaluate the review procedures that the control owners performed including the criteria that the control owners used to identify items for follow up and whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing controls that consisted of the issuer's review of income tax accounts. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control that included the issuer's review of the valuation allowance for its deferred tax assets related to its domestic and foreign operations. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the evidence the issuer used to determine whether a valuation allowance was necessary. (AS 2201.42 and .44)

The issuer reported an income tax benefit from tax exemptions that a foreign tax authority granted the issuer. These exemptions were subject to compliance with certain conditions. The following deficiencies were identified: · The firm selected for testing a control that consisted of the review of an analysis that the issuer used to determine whether it met those conditions. The firm did not evaluate the specific review procedures that the control owner performed to assess the issuer's compliance with those conditions. (AS 2201.42 and .44)

With respect to the issuer's transfer pricing related to intercompany transactions the following deficiencies were identified: · The firm selected for testing a control over the issuer's monitoring of compliance with its transfer pricing methodology including the review of whether all transactions introducing transfer-pricing risk had been identified for evaluation. The firm did not evaluate the specific review procedures that the control owner performed to (1) determine whether the issuer identified a complete population of transactions with potential transfer-pricing implications for review and (2) assess the issuer's compliance with its transfer-pricing methodology for the transactions that were identified including the control owner's review of intercompany margins. (AS 2201.42 and .44)

With respect to the issuer's disclosures related to its permanent reinvestment of foreign earnings the following deficiencies were identified: · The firm selected for testing a control that included the issuer's review of its disclosures related to these earnings. The firm did not evaluate the specific review procedures that the control owner performed to evaluate the potential effects of the changes in federal tax laws on the issuer's disclosures. (AS 2201.42 and .44)