Form 10-K for the Fiscal Year Ended December 31, 2022
We note that you present Total Segment Earnings as a GAAP measure. Please note the presentation of a total segment profit or loss measure in any context other than the ASC 280 required reconciliation in the financial statement footnotes is considered a presentation of a non-GAAP measure. Furthermore, as a result, your Total Adjusted Segment Earnings non-GAAP measure currently is not reconciled to a GAAP measure.Rest of the question
Show us how you will revise your presentation in future filings. Refer to Question 104.04 of the Compliance & Disclosure Interpretations for Non-GAAP Financial Measures. 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.
We acknowledge the Staff's comment, and in future filings, we will discontinue the presentation of total segment profit or loss as a GAAP measure in any context other than the ASC 280 required reconciliation in the financial statement footnotes. Beginning with the Company's Form 10-Q for the quarter ended March 31, 2023, we will present and reconcile the GAAP measure “Earnings before provision for income taxes” to total segment earnings and adjusted segment earnings.Read in the reply ↗Rest of the answer
For your information, we have included in tabular format the presentation we will use in future financial reports.
The following is a reconciliation of reported earnings before provision for income taxes to segment earnings and adjusted segment earnings:
Twelve Months Ended
December 31,
2022 2021
Earnings Before Provision for Incomes Taxes (GAAP) $ 223.7 $ 625.6
Add: Corporate Expense(1)
128.9 52.1
Add: Interest Expense 9.4 4.3
Total Segment Earnings $ 362.0 $ 682.0
North America(2)
$ 266.0 $ 590.8
Rest of World 96.3 91.4
Inter-segment earnings elimination (0.3) (0.2)
Additional Information
(1)Corporate Expense
$ (128.9) $ (52.1)
Pension settlement expense, before tax 70.5 —
Pension expense (income), before tax 2.0 (2.6)
Terminated acquisition-related expenses, before tax 4.3 —
Adjusted Corporate Expense (non-GAAP) $ (52.1) $ (54.7)
(2)North America
First report after the company's reply of 2023-04-14: 10-Q filed 2023-04-28 ↗, against the 10-Q filed 2022-10-28 ↗.
Tickdelta does not hold the text of both reports, so they are not compared here.
Also in this review: closing letter, 2023-04-25