Subject: File No. S7-15-16
From: Morris Pearl, 7203464
Affiliation: Chair of the Patriotic Millionaires, former Managing Director at BlackRock Inc.

November 2, 2016

Thank you for the opportunity to comment on the proposed Disclosure Update and Simplification Rule.

Disclosure of appropriate information to investors is critically important both for investors to properly assess risk and for markets at large to function properly.

Investors (owners) of companies and anyone researching those companies for investment opportunities have reasonable need for multinational corporations international information. There is significant risk (both reputational and operational) to companies that avoid paying taxes in jurisdictions wherein they have significant activities.

The question is not of legality - the government already gets country-by-country tax disclosure as part of a companys tax returns - but of policy.

International corporate tax strategies, in particular, have become more complicated. The amounts of money involved have grown exponentially in recent years. The associated risks have also risen.

The competitiveness of a firm relies on the health, strength, and growth of the firm - not on tax disclosures.

I urge the Securities and Exchange Commission (SEC) to use the opportunity of this rulemaking to require multinational entities to report, on a country-by-country basis, the following:

profit or loss before taxes
income tax accrued for the current year
revenues from unrelated parties, related parties, and in total
income tax paid (on a cash basis)
effective tax rate
stated capital
accumulated earnings
number of employees and
tangible assets other than cash or cash equivalents.

Kindly see the attached New York Times opinion editorial and a Columbia Tax Journal submission for a more detailed explanation of the risks and benefits of increased tax disclosures.

Copyrighted material redacted. Author cites:
Pearl, Morris. "How Companies Like Apple Dodge Taxes and Their Own Investors." The New York Times. The New York Times, 21 Sept. 2016. Web. 04 Nov. 2016. http://www.nytimes.com/2016/09/21/opinion/how-companies-like-apple-dodge-taxes-and-their-own-investors.html?_r=0.