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Published on July 5, 2011
| Steven P. Whaley Senior Vice President and Controller |
702 SW 8th Street Bentonville, AR 72716 Phone 479.273.4000 www.walmart.com |
July 5, 2011
Mr. Andrew D. Mew
Accounting Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549
| Re: | Wal-Mart Stores, Inc. |
Form 10-K for Fiscal Year Ended January 31, 2011
Filed March 30, 2011
File No. 1-6991
Dear Mr. Mew:
This letter is in response to your letter dated June 22, 2011, addressed to Mr. Charles M. Holley, Jr., Executive Vice President and Chief Financial Officer of Wal-Mart Stores, Inc. (the Company). For ease of review, we have reproduced below in bold-faced type the comments of the staff of the Securities and Exchange Commission (the Commission) contained in that letter and have provided our response in regular type following each comment.
Form 10-K for the Fiscal Year Ended January 31, 2011
Exhibit 13
Item 8. Financial Statements and Supplementary Data
Note 10. Income Taxes, page 39
| 1. | We note your response to comment six in our letter dated May 17, 2011. Please clarify for us how your repatriation of international earnings for each of the last three years in the form of cash distributions and deemed inclusions under the U.S. tax code is consistent with demonstrating indefinite postponement of remittances from your foreign subsidiaries. It appears that at least some of your international earnings are intended to be remitted each year for which income taxes have not been accrued. Please see ASC 740-30-25 paragraphs 17 and 19. |
Letter to the Securities and Exchange Commission
July 5, 2011
Page 2
The indefinite reinvestment criterion of ASC 740-30-25-17 does not require the exception to be applied on an all-or-nothing basis and we have not made such an assertion on all of our foreign subsidiaries earnings. The foreign earnings repatriated to the U.S. over the last three years came from subsidiaries for which we do not intend to indefinitely reinvest earnings. For these earnings, we have accounted for the U.S. income tax provision impacts in the periods when the amounts were earned and did not rely on the exception provided in ASC 740-30-25.
If you have any questions about the Companys response to your additional comment or need further information, please contact the undersigned at (479) 204-8263.
| Sincerely, |
| /s/ Steven P. Whaley Steven P. Whaley |
| Senior Vice President and Controller |
| cc: | Donna Di Silvio Staff Accountant Securities and Exchange Commission
Chris Chase Attorney-Advisor Securities and Exchange Commission
Charles M. Holley, Jr. Executive Vice President and Chief Financial Officer Wal-Mart Stores, Inc.
Audit Committee of the Board of Directors Wal-Mart Stores, Inc. |