April 21, 2017
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
RE: | MACOM Technology Solutions Holdings, Inc. |
Form10-K for the Fiscal Year Ended September 30, 2016
Filed November 17, 2016
Form8-K filed January 31, 2017
FileNo. 001-35451
Dear Mr. Kuhar:
MACOM Technology Solutions Holdings, Inc. (the “Company”, “we” or “us”) hereby submits a response to the supplemental comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) contained in the Staff’s letter dated April 19, 2017 (the “Comment Letter”), relating to the above-referenced Form10-K and Form8-K. The headings of this letter correspond to the headings contained in the Comment Letter, and to facilitate your review, we have reproduced below the original text of the Staff’s comments, in bold, followed by the Company’s response.
Form8-K filed January 31, 2017
Exhibit 99.1
1. | We note your response to comment 5 and related disclosures in your Form8-K regarding the tax effect of yournon-GAAP adjustments. Please revise future filings to clearly explain how you determined your adjustednon-GAAP income tax rate and explain the nature of any significant differences between your effective income tax rate determined under GAAP and your adjustednon-GAAP income tax rate. Refer to Question 102.11 of the updatedNon-GAAP Compliance and Disclosure Interpretations issued on May 17, 2016. |
Response: The Company advises the Staff that in future filings, we will clearly explain how we determine our adjustednon-GAAP income tax rate and explain the nature of any significant differences between our effective income tax rate determined under GAAP and our adjustednon-GAAP income tax rate.
If we can facilitate the Staff’s review, or if the Staff has any questions on any of the information set forth herein, please telephone me at (978)656-2753. Thank you again for your time and consideration.
Sincerely, |
/s/ Robert J. McMullan |
Senior Vice President and Chief Financial Officer |
Cc: | Marko Zatylny, Ropes & Gray LLP |