AOSA. O. Smith

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.

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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.

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

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