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June 30, 2017
Via EDGAR
Mr. Brian Cascio
Accounting Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: |
Bruker Corporation |
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Form 10-K for the Fiscal Year Ended December 31, 2016 |
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Filed March 1, 2017 |
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File No. 000-30833 |
Dear Mr. Cascio:
This letter is being filed by Bruker Corporation (the Company) in response to comments of the staff (the Staff) of the Securities and Exchange Commission (the Commission) set forth in your letter dated June 26, 2017 (the Comment Letter) to Anthony L. Mattacchione, Chief Financial Officer and Senior Vice President of the Company.
Our response to the Staffs comment contained in the Comment Letter is set forth below. For convenient reference, the Staffs comment is set forth in italics before the response.
Form 10-K for the Fiscal Year Ended December 31, 2016
Item 7. Managements Discussion And Analysis of Financial Condition and Results of Operations
1. We note the significant impact of the foreign tax rate differential on your effective tax rate on page 100. In future filings, revise to explain the impact of non-U.S. lower taxed jurisdictions on your effective tax rate, including a discussion of the primary taxing jurisdictions where your foreign earnings are derived, the location of tax holidays and the relevant statutory rates in those jurisdictions. Discuss any uncertainties relating to the income tax rates or benefits you currently receive in those jurisdictions. Refer to Item 303(a)(3) of Regulation S-K.
Response:
We respectfully acknowledge the Staffs comment and advise the Staff that in our future filings we will expand our disclosures included in Managements Discussion and Analysis of Financial Condition and Results of Operations to explain, to the extent material, the impact of non-U.S. lower taxed jurisdictions on our effective tax rate. Specifically, we will add appropriate discussion of the primary taxing jurisdictions where our foreign earnings are derived, the location of tax holidays, if any, and the relevant statutory rates in those jurisdictions, as well as any material uncertainties relating to the income tax rates or benefits we receive in those jurisdictions.
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If you would like to discuss the Companys response, or any further questions that you may have, please do not hesitate to contact the undersigned at (978) 663-3660.
Very truly yours,
/s/ ANTHONY L. MATTACCHIONE |
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Anthony L. Mattacchione |
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Chief Financial Officer and Senior Vice President |
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cc: |
Securities and Exchange Commission |
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Andri Carpenter |
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Caleb French |
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Geoff Kruczek |