United States securities and exchange commission logo
April 12, 2021
Gary Smalley
Chief Financial Officer
Tutor Perini Corporation
15901 Olden Street
Sylmar, CA 91342
Re: Tutor Perini
Corporation
Form 10-K for the
year ended December 31, 2020
File No. 001-06314
Dear Mr. Smalley:
We have reviewed your filing and have the following comment. In
our comment, we
may ask you to provide us with information so we may better understand
your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for the year ended December 31, 2020
Note 7. Financial Commitments, page F-27
1. We note the repayment
of a portion of the Company's convertible notes that occurred on
August 19, 2020. In
order to better understand the Company's accounting for this
transaction, please
tell us the following:
the amount of
consideration attributable to the fair value of the liability component
immediately before
extinguishment and how you accounted for the difference
between the fair
value and the carrying value of the liability component that may
have resulted in a
gain or loss on debt extinguishment. Refer to ASC 470-20-40-
20(b);
whether the
deferred taxes presented on your table on page F-30 represent the basis
difference
associated with the liability component that was initially recognized as an
adjustment to APIC
consistent with the guidance in ASC 470-20-25-27 and when the
Company is
expecting such temporary difference to reverse; and
what
consideration you gave to reversing a portion of the $18.8 million deferred tax
Gary Smalley
Tutor Perini Corporation
April 12, 2021
Page 2
liability due to the previous amortization of the debt discount
and whether an
additional amount should be reversed due the partial redemption
of the convertible
notes on August 19, 2020. Refer to the example in ASC
470-20-55-71 through 55-
82.
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 Ameen Hamady at 202-551-3891 or Kristi Marrone at
202-551-3429 if
you have questions.
FirstName LastNameGary Smalley Sincerely,
Comapany NameTutor Perini Corporation
Division of
Corporation Finance
April 12, 2021 Page 2 Office of Real
Estate & Construction
FirstName LastName