July 26, 2019

Sean Douglas
Chief Financial Officer
Huntsman CORP
Huntsman International LLC
10003 Woodloch Forest Driv
The Woodlands, Texas 77380

       Re: Huntsman CORP
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed: February 12, 2019
           Form 10-Q for the Quarterly Period Ended March 31, 2018
           Filed: April 30, 2019
           File No. 001-32427
           Huntsman International LLC
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed: February 12, 2019
           Form 10-Q for the Quarterly Period Ended March 31, 2018
           Filed: April 30, 2019
           File No. 333-85141

Dear Mr. Douglas:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018

Note 4. Discontinued Operations and Business Disposition, page F-27

1.    We note that notwithstanding your remaining 49% interest in Venator, you
continue to
      reflect this business as discontinued operations. Please tell us how you
considered the
 Sean Douglas
Huntsman CORP
July 26, 2019
Page 2
         nature, time frame and extent of this continuing involvement in
Venator in your
         determination that the disposition of your 51% interest resulted in a
strategic shift that has
         had (or will have) a major effect on your results of operations and
financial results such
         that this disposition qualified for discontinued operations
presentation. Refer to ASC 205-
         20-45-1B. Please ensure your response addresses any changes to your
plans subsequent to
         Venator's IPO and address the guidance in ASC 205-20-45-1E.f. Also,
explain the extent
         of your involvement in Venator's operations subsequent to it's IPO and
subsequent to
         your deconsolidation. Finally, address your intentions with regard to
the time frame of
         your continued involvement and explain how you contemplated the
guidance in ASC 205-
         20-45-1E.e. In this regard, we note from your earnings calls that the
determination to sell
         your remaining interest is dependent on the future stock price of
Venator.

Form 10-Q for the Quarterly Period Ended March 31, 2019

Note 4. Discontinued Operations and Business Dispositions, page 20

2.       We note that the $75 million fair value adjustment to your investment
in Venator appears
         material to your results of operations. Please tell us what
consideration was given to
         providing the disclosures required by Rule 4-08(g) of Regulation S-X
for this investment.
          In this regard, we believe that the income test set forth in Rule
1-02(w) should be
         computed using as the numerator the change in the fair value reflected
in your income
         statement rather than the equity in earnings of the investee.
        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.

        You may contact Tracey McKoy, Staff Accountant, at (202)551-3772 or
Jeanne Baker,
Assistance Chief Account, at (202) 551-3691 or Terence O'Brien, Accounting
Branch Chief, at
(202) 551-3355 if you have questions regarding comments on the financial
statements and
related matters.



                                                                Sincerely,
FirstName LastNameSean Douglas
                                                                Division of
Corporation Finance
Comapany NameHuntsman CORP
                                                                Office of
Manufacturing and
July 26, 2019 Page 2                                            Construction
FirstName LastName