SRSEC Reporting Desk

SMITH A O CORP (AOS) – SEC staff letter

2026-04-21 · Re: A.O. Smith Corporation Form 10-K for the year ended December 31, 2025 · Accession 0000000000-26-004028 · 1 staff comment(s) issued

Company response(s): 2026-04-29

MD&A: Results & Known TrendsIncome TaxesDebt, Equity & Derivatives

2026-04-21 · A.O. Smith Corporation Form 10-K for the year ended December 31, 2025 · Comment 1 · Income Taxes, page 50 Partly revised / explained
Staff comment: Your MD&A attributes the 2025 effective tax rate change to reduced U.S. cross-border taxes, yet your rate reconciliation lacks a corresponding category. Additionally, you cite a “one-time tax adjustment” from a tax law change as a cash flow benefit, but this is not separately identified in your reconciliation as required by ASC 740-10-50-12A(a). Please tell us and disclose in future filings the details of the specific tax law change. Also, clarify how these items are currently reflected in your reconciliation and why they do not warrant separate presentation. letter →
Company response: We respectfully acknowledge the Staff's comment and are providing additional details and references to identify the materiality considerations that we used when determining the items to disclose in MD&A, as well as the referenced rate reconciliation contained within Note 14, Income Taxes. The “one-time tax adjustment” referenced as a cash flow benefit on page 23 in Liquidity and Capital Resources relates to changes to the timing of deduction of previously capitalized domestic research and development expenses under IRC Section 174 from the One Big Beautiful Bill Act. We are deducting the remaining unamortized domestic research and development costs over two years (half in 2025 and the other… response letter →
MD&A: Results & Known TrendsIncome TaxesDebt, Equity & Derivatives

Full letter on EDGAR → · Filing index · All SMITH A O CORP (AOS) correspondence

MD&A: Results & Known Trends – what to check: Quantify drivers of changes (price vs. volume), discuss known trends and uncertainties, and avoid repeating the financial statements.

Income Taxes – what to check: Explain valuation allowance positive/negative evidence and the drivers of effective rate changes.

Debt, Equity & Derivatives – what to check: Walk through the ASC 480/815/470 analysis for convertibles, warrants and modifications, citing the specific guidance and conclusions.

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