Juan Figuereo

Executive Vice President & Chief Financial Officer

Revlon, Inc.

One New York Plaza

New York, NY 10004

Phone: 212-527-6645

E-mail: juan.figuereo@revlon.com

 

                                                                                                                                                            

Mr. John Cash

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 

                                                                

Dear Mr. Cash:

Please find below the response of Revlon, Inc. (“Revlon”) to the comments in the letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated June 1, 2016 (the “Comment Letter”), relating to Revlon, Inc.’s Form 10-K for the year ended December 31, 2015, filed with the Commission on February 26, 2016.  For the Staff’s convenience, we have repeated the Staff’s comment in the Comment Letter below (in italic type) before Revlon’s response.

 

COMPANY RESPONSE: The Company provides a valuation allowance for those deferred tax assets for which, in the opinion of the Company's management, it is more likely than not that the deferred tax assets will not be realized. At December 31, 2015, the deferred tax valuation allowance primarily represented amounts for foreign tax loss carryforwards and certain U.S. state and local tax loss carryforwards. After considering all available evidence, including recent history of cumulative income, improved earnings trends and expected taxable income, and no history of net operating losses expiring unused, as well as the absence of any significant negative evidence, the Company released an $18.4 million valuation allowance against certain deferred tax assets in the U.K.  Overall, the deferred tax valuation allowance decreased by $10.0 million during 2015, which was primarily due to the reduction of the Company's valuation allowance in the U.K., partially offset by additional valuation allowances on current period net operating losses incurred in certain jurisdictions.

 

 

 

The Company will revise its future filings to include a discussion, in substantially the form as summarized above, related to the details surrounding the reduction of the Company’s valuation allowance on deferred tax assets in 2015 or in future periods, as applicable.

The Company hereby acknowledges to the Commission that:

 

 

Thank you for your consideration of Revlon’s responses to the Staff’s Comment Letter and please do not hesitate to call the undersigned at (212) 527-6645, or Brett Nadritch or David Zeltner at Milbank, Tweed, Hadley & McCloy LLP at (212) 530-5301, if you have any questions or need any additional information.