ACNAccenture

We note that you present effective tax rate and diluted earnings per share excluding business optimization costs and investment gain in your results of operations discussion. It does not appear that you have clearly labeled each as a non-GAAP measure. Where applicable, please revise your presentation to fully comply with Item 10(e)(1)(i) of Regulation S-K.

Rest of the question

Also refer to Question 102.10(b) of our Compliance and Disclosure Interpretations on Non-GAAP Financial Measures with regards to your reconciliation of diluted earnings per share.

to the Staff’s comment, in future filings, beginning with our Quarterly Report for the quarterly period ended February 29, 2024 (the “Q2 2024 Form 10-Q”), we will more clearly identify these measures as non-GAAP measures by labeling the metrics “adjusted” effective tax rate and “adjusted” diluted earnings per share, respectively, whenever used. Additionally, we will revise our tabular presentation of diluted earnings per share to also present the reconciliations in a tabular form before the comparison of non-GAAP disclosures. Read in the reply ↗

Please present the income tax effects of the non-GAAP adjustments as a separate line item in your reconciliation of adjusted earnings per share and provide a footnote to explain how the income tax effects were calculated. Refer to Question 102.11 of our Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.

We acknowledge the Staff’s comment regarding the presentation of income tax effects in our reconciliation of adjusted earnings per share, with reference to Question 102.11 of the Compliance and Disclosure Interpretations on non-GAAP Financial Measures. In future filings, beginning with the Q2 2024 Form 10-Q, we will present the income tax effect of non-GAAP adjustments as a separate line item in our reconciliation of adjusted earnings per share, with a footnote to explain how the income tax effects were calculated. Read in the reply ↗