September 27, 2011
VIA EDGAR
Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-3628
| Re: | Alterra Capital Holdings Limited |
| Form 10-K for Fiscal Year Ended December 31, 2010 |
| Filed February 25, 2011 |
| File No. 000-33047 |
Dear Mr. Rosenberg:
We are responding to the comment letter from the Staff of the Securities and Exchange Commission (the “Commission”), dated September 15, 2011, concerning Alterra Capital Holdings Limited’s (the “Company” or “we”) Annual Report on Form 10-K for the fiscal year ended December 31, 2010.
For your convenience, we have repeated the Staff comment (displayed in italics) immediately before our response. All numbers are in thousands except where noted otherwise.
Notes to Consolidated Financial Statements
15. Income Taxes, page 157
| 1. | Please provide us proposed disclosure to be included in future periodic filings to separately disclose the income before income tax expense for domestic and foreign operations. Refer to Rule 4-08(h) of Regulation S-X. |
Response:
The Company is domiciled in Bermuda. Accordingly, we consider its “domestic” location to be Bermuda.
Our proposed disclosure is included asAppendix A to this letter. We will include this proposed disclosure in our future periodic filings, as appropriate.
In connection with our response to the Staff’s comment, we acknowledge that:
| • | We are responsible for the adequacy and accuracy of the disclosure in our filings; |
| • | Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| • | We may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please do not hesitate to contact the undersigned at (441) 294-2251 with any questions or comments regarding this response.
| Very truly yours, |
| /s/ Joseph W. Roberts |
| Joseph W. Roberts |
| Executive Vice President |
| Chief Financial Officer |
Appendix A:
The Company’s income (loss) before income tax expense (benefit) was distributed as follows for the years ended December 31, 2011, 2010 and 2009, respectively:
2011 | 2010 | 2009 | ||||||||||||
Domestic: | ||||||||||||||
| Bermuda | $ | $ | 295,289 | $ | 228,744 | |||||||||
Foreign: | ||||||||||||||
| United States | (7,787 | ) | (8,552) | |||||||||||
| Ireland | 1,977 | 10,799 | ||||||||||||
| United Kingdom | 16,615 | 24,421 | ||||||||||||
| Other | 397 | 824 | ||||||||||||
|
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Income (loss) before income taxes | $ | $ | 306,491 | $ | 256,236 | |||||||||
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