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                            June 8, 2023

       Patrick W.D. McCann
       Executive Vice-President and Chief Financial Officer
       Magna International Inc.
       337 Magna Drive
       Aurora, Ontario, Canada L4G 7K1

                                                        Re: Magna International
Inc.
                                                            Form 40-F for the
Year Ended December 31, 2022
                                                            Filed March 31,
2023
                                                            Form 40-F/A for the
Year Ended December 31, 2022
                                                            Filed April 27,
2023
                                                            File No. 001-11444

       Dear Patrick W.D. McCann:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 40-F/A for the Year Ended December 31, 2022

       Exhibit 2
       Note 1. Significant Accounting Policies
       Revenue Recognition, page 5

   1.                                                   We note your discussion
of the products offered by each of your reporting segments on
                                                        pages 31 through 38 of
Exhibit 1. Please tell us how you considered the guidance in ASC
                                                        606-10-50-5 when
determining your disclosures related to the disaggregation of revenue
                                                        in your financial
statements. In addition, tell us how you considered the guidance in ASC
                                                        280-10-50-40 in
concluding on the need to present revenues from external customers for
                                                        each product and
service or each group of similar products and services.
 Patrick W.D. McCann
FirstName  LastNamePatrick W.D. McCann
Magna International Inc.
Comapany
June 8, 2023NameMagna International Inc.
June 8,
Page  2 2023 Page 2
FirstName LastName
Exhibit 3
Management's Discussion and Analysis of Results of Operations and Financial
Position
Results of Operations, page 5

2.       In future filings, please discuss in greater detail the business
reasons for the changes
         between periods in your sales and expense line items. In addition,
enhance your
         disclosure to also discuss the business reasons for the changes
between periods in the
         significant line items of each of your segments. In doing so, disclose
the amount of each
         significant change in line items between periods and the business
reasons for it. In
         circumstances where there is more than one business reason for the
change, quantify the
         incremental impact of each individual business reason discussed on the
overall change in
         the line item. For example, your disclosure on page 5 indicates that
sales increased
         primarily due to (i) the launch of new programs during or subsequent
to 2021, (ii) higher
         global light vehicle production and (iii) customer price increases to
recover certain higher
         production input costs, but it is unclear how significantly each of
these factors impacted
         your sales. Please refer to Item 303(a)(3) of Regulation S-K for
further information.
3.       You state that you continue to experience elevated inflation in all
markets in which you
         operate, with higher commodity, energy, labour, freight and other
production input pricing
         expected to persist throughout 2023 and 2024. In future filings,
please expand to identify
         the principal factors contributing to the inflationary pressures the
company has
         experienced and clarify the resulting impact to the company.
4.       Please further discuss in future filings whether supply chain
disruptions materially affect
         your outlook or business goals. Specify whether these challenges have
materially
         impacted your results of operations or capital resources and quantify,
to the extent
         possible, how your sales, profits, and/or liquidity have been
impacted.
5.       We note that you have experienced labour and other operational
inefficiencies at your
         facilities as a result of your production lines being stopped/started
largely due to supply
         constraints. Please revise your disclosure in future filings to
discuss known trends or
         uncertainties resulting from mitigation efforts undertaken, if any.
Explain whether any
         mitigation efforts introduce new material risks, including those
related to product quality,
         reliability, or regulatory approval of products.
 Patrick W.D. McCann
FirstName  LastNamePatrick W.D. McCann
Magna International Inc.
Comapany
June 8, 2023NameMagna International Inc.
June 8,
Page  3 2023 Page 3
FirstName LastName
       In closing, 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 Jeffrey Gordon at 202-551-3866 or Martin James at
202-551-3671 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing