MCDMcDonald's

The consolidated statement of comprehensive income discloses amounts in regard to defined benefit pension plans. Please explain to us why you have not provided applicable disclosure for these plans in accordance with ASC 715-20-50.

We respectfully acknowledge the Staff’s comment, and we advise the Staff that the referenced amounts disclosed in the Consolidated Statement of Comprehensive Income are related to the Company’s UK defined benefit pension plan (the “UK Plan”) which is not material to the financial statements. Accordingly, the Company has not provided the related disclosures set forth in ASC 715-20-50.

Rest of the answer

We have summarized the primary quantitative and qualitative factors that the Company’s management evaluated in arriving at this conclusion, as follows:

•The UK Plan is in an overfunded position with an ending net noncurrent asset balance of $0.1 million and $26.7 million recognized in the Consolidated Balance Sheet as of

December 31, 2023 and December 31, 2022, respectively. On a gross basis, the actuarially determined projected benefit obligation and fair value of plan assets as of December 31, 2023, were approximately $579.3 million each (~1% of total assets and total liabilities). For the comparative period ended December 31, 2022, the projected benefit obligation and fair value of plan assets were $525.6 million and $552.3 million, respectively (~1% of total assets and total liabilities).

•The pension benefit, recognized primarily in nonoperating income in the Consolidated Statement of Income, for the years ended December 31, 2023 and 2022 was $37.4 million (~0.4% of income before provision for income taxes) and $5.3 million (~0.1% of income before provision for income taxes), respectively. For the year ended December 31, 2021, the pension cost was $7.1 million (~0.1% of income before provision for income taxes).

•Employer contributions to the UK Plan were $20.8 million, $20.7 million, and $23.7 million for the years ended December 31, 2023, 2022, and 2021, respectively (less than 0.5% of cash provided by operations for all comparative periods presented).

•The 2024 projected pension benefit and employer contributions are moderately lower than the 2023 actual amounts, and therefore are projected to remain immaterial.

•The UK Plan has been frozen to new entrants since 2002 and includes a limited number of participants residing in one market.

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