![]() |
BARRICK GOLD CORPORATION
Brookfield Place,
TD Canada Trust Tower
Suite 3700, 161 Bay Street
P.O. Box 212
Toronto, Ontario M5J 2S1
Canada
|
Tel: 416.861.9911
Fax : 416.861.2492
|
Attention:
|
Craig Arakawa
Accounting Branch Chief
Office of Beverages, Apparel and Mining
Securities and Exchange Commission
|
Re:
|
Barrick Gold Corporation
Form 40-F for the Fiscal Year Ended December 31, 2017
Filed March 26, 2018
File No. 001-09059
|
|
Page 1
|
|
|
1. |
We note the disclosure included in your response to comment 2 states that the total consideration received by Barrick and Kinross implied a fair value of $1.2 billion for 100 percent of the Cerro Casale Project and as a result you reversed previously recorded impairment charges of $1.12 billion in the first quarter of 2017. Based on your disclosures in your Form 40-Fs for the years ended December 31, 2014 and 2016, we note that previous impairment charges taken on Cerro Casale in 2014 totaled $1.46 billion and that the remaining carrying value of the project was $444 million as of December 31, 2016. Based on this information, it would appear that the total of the impairment reversal and existing carrying value of Cerro Casale at the time of the reversal exceeded the implied fair value of $1.2 billion. Please clarify how you determined the amount of the impairment reversal in light of these observations.
|
● |
The carrying value of the Cerro Casale Project cash generating unit (“CGU”) immediately prior to the date of the impairment reversal was $518 million.
|
● |
The total consideration received in connection with the sale of 50% of the Cerro Casale Project to Goldcorp Inc. announced on March 28, 2017, implied a fair value of $1.2 billion for 100% of the Cerro Casale Project.
|
● |
Based on this implied fair value, in the first quarter of 2017, we recognized a partial impairment reversal, on a pre-tax basis, of $1.12 billion of the Cerro Casale Project CGU. This impairment reversal resulted in a corresponding deferred tax liability of $429 million. As a result, the carrying value of the Cerro Casale Project CGU, on an after-tax basis, increased to $691 million ($1.12 billion less $429 million).
|
● |
The carrying value of the Cerro Casale Project CGU immediately prior to the impairment reversal of $518 million, increased by the net after-tax impairment reversal of $691 million, resulted in a carrying value of the Cerro Casale Project CGU of $1,209 million immediately following the impairment reversal, consistent with the implied fair value of the Cerro Casale Project of $1.2 billion.
|
|
Page 2
|
![]() |
|
Cerro Casale Project CGU carrying value immediately prior to impairment reversal
|
$518
|
|
Impairment reversal (pre-tax)
|
$1,120
|
|
Deferred tax liability (as a result of impairment reversal)
|
$(429)
|
|
Cerro Casale Project CGU carrying value immediately following impairment reversal
|
$1,209
|
(a) |
You noted the remaining carrying value of the Cerro Casale Project was $444 million as of December 31, 2016. This $444 million figure is the value of the property, plant and equipment of the Cerro Casale Project as disclosed in note 19(a) of the Annual Report on Form 40-F for the fiscal year ended December 31, 2016 (the “2016 40-F”). The carrying value of the Cerro Casale Project CGU was $516 million as of December 31, 2016 as disclosed in note 21 of the 2016 40-F. Further, as noted above, immediately prior to the impairment reversal the carrying value of the Cerro Casale Project CGU had increased to $518 million as at June 30, 2017.
|
(b) |
You also noted that we recorded an impairment reversal of $1.12 billion. This impairment reversal is on a pre-tax basis. As a result of this impairment reversal, there is a corresponding deferred tax liability of $429 million. The net after-tax impairment reversal is therefore $691 million.
|
|
Page 3
|
![]() |
|
Sincerely,
|
|
/s/ Catherine P. Raw
|
|
Catherine P. Raw
|
|
Executive Vice President and Chief Financial Officer
|
|
Barrick Gold Corporation
|
c.c.:
|
Kelvin Dushnisky, President, Barrick Gold Corporation
Rich Haddock, Senior Vice President and General Counsel, Barrick Gold Corporation
Audit Committee, Barrick Gold Corporation
John Donnelly, PricewaterhouseCoopers LLP
|
|
Page 4
|
![]() |
|