BERKSHIRE HATHAWAY INC.
3555 FARNAM STREET
OMAHA, NEBRASKA 68131
TELEPHONE (402) 346-1400
FAX (402) 346-3375
July 7, 2021
Hugh West and Robert Klein
Division of Corporation Finance, Office of Finance
United States Securities and Exchange Commission
Washington, D.C. 20549
| Re: | Berkshire Hathaway Inc. |
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed March 1, 2021
File No. 001-14905
Dear Messrs. West and Klein:
The purpose of this letter is to respond to your letter dated June 29, 2021. To assist you in reviewing our response, we preceded our response with a copy (in bold type) of the point as stated in your letter.
Form 10-K for the Fiscal Year Ended December 31, 2020
Item 7. Managements Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies
Other Critical Accounting Policies, page K-63
| 1. | We note your disclosure related to Goodwill and indefinite-lived intangible asset impairment here and on page 40 of your Form 10-Q for the Quarterly Period ended March 31, 2021. In regards to your goodwill and the related impairment evaluation, please revise your future filings to identify the at-risk reporting units (i.e., fair value is not substantially in excess of the carrying value) and disclose the percentage by which fair value exceeded carrying value as of the date of the most recent test and the amount of goodwill allocated to the reporting unit. |
In future filings beginning with the quarterly report on Form 10-Q for the period ended June 30, 2021, we will revise disclosures to identify the at-risk reporting units (i.e. where we believe the fair value is not substantially in excess of the carrying value) and disclose the percentage by which fair value exceeded carrying value as of the date of the most recent impairment test and the amount of goodwill allocated to the reporting unit.
Should you have any questions or further comments, please contact the undersigned at 402-978-5423.
| Very truly yours, | ||
| BERKSHIRE HATHAWAY INC. | ||
/s/ Marc D. Hamburg | ||
By Marc D. Hamburg Senior Vice President – Chief Financial Officer
cc: Daniel J. Jaksich, Vice President – Controller | ||
