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CORRESP Filing
Scorpio Tankers (STNG) CORRESPCorrespondence with SEC
Filed: 17 Mar 14, 12:00am
Seward & Kissel llp ONE BATTERY PARK PLAZA NEW YORK, NEW YORK 10004 | ||
TELEPHONE: (212) 574-1200 FACSIMILE: (212) 480-8421 WWW.SEWKIS.COM | 901 K Street, NW WASHINGTON, D.C. 20001 TELEPHONE: (202) 737-8833 FACSIMILE: (202) 737-5184 |
March 17, 2014 |
1. | We note from your response to our prior comment 5 that you contributed contracts for 11 VLGCs under construction, options to build two additional VLGCs along with $1.9 million in cash to Dorian and as a result, you obtained an equity interest in Dorian of 30%. We also note from your response that you valued the shares received based on the price of those shares on the closing date of the transaction, in accordance with IAS 27. In light of your disclosures in your Form 6-K furnished on February 24, 2014, that during the three months ended December 31, 2013, you recognized a gain of $41.4 million as a result of this transaction, please provide us details as to how you determined or calculated the $41.4 million gain recognized. |
In thousands of US dollars | Gain on sale of assets | |||
Installment payments on 11 VLGCs made through November 26, 2013 | $ | 83,070 | ||
Additional cash and other capitalized costs | 2,300 | (1) | ||
Selling costs | 7,690 | (2) | ||
Total book value of assets contributed | 93,060 | |||
Value of initial shares received at closing | 134,435 | (3) | ||
Gain on sale | $ | 41,375 |
(1) | Represents additional cash consideration and the contribution of certain capitalized costs that were incurred on these vessels under construction prior to closing. |
(2) | Represents legal and advisory fees relating to the transaction, including commissions paid to Scorpio Services Holdings Inc., a related party affiliate. |
(3) | The value of our initial investment was determined based on the 39,952,123 shares obtained in the transaction multiplied by the closing price of Dorian on the Norwegian Over the Counter exchange ('NOTC') at November 26, 2013 of NOK 20.5, using an NOK/USD exchange rate of 6.0923 NOK/USD at that date. |
Very truly yours, SEWARD & KISSEL, LLP By: Edward S. Horton Edward S. Horton, ESQ | |
Brian Lee Chief Financial Officer Scorpio Tankers Inc. |