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In our comment letter, we express support for the FASB’s efforts to improve income tax disclosures. We suggest clarifying the application of the 5% threshold to the rate reconciliation table and categorization of certain items in the rate reconciliation table (i.e., foreign tax credits and alternative minimum taxes). We also encourage the FASB staff to work with the SEC staff to eliminate potential redundancies between the income tax disclosure requirements and Regulation S-X 4-08(h) once the guidance is finalized.
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