November 25, 2020
Gus Rodriguez, Accounting Branch Chief
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street N.E.
Washington, DC 20549
| Re: | Teekay LNG Partners L.P. Form 20-F for Fiscal Year Ended December 31, 2019 Filed April 9, 2020 Form 6-K Filed August 13, 2020 File No. 001-32479 |
Dear Mr. Rodriguez:
We have reviewed your letter to us of November 13, 2020 setting forth staff comments on Teekay LNG Partners L.P.’s (“Teekay LNG” or the “Partnership”) Form 6-K filed August 13, 2020. This letter responds to the comment made by the staff in your letter. For your convenience, the response has been keyed to the comment.
Form 6-K Filed August 13, 2020
Definitions and Non-GAAP Financial Measures, page 6
SEC Comment
| 1. | We have reviewed your response to comment 1. Your presentation of the non-GAAP measure Adjusted Revenues includes revenues based on your proportionate economic ownership of each vessel owned by your equity-accounted joint ventures. Presentation of revenue based on proportionate consolidation is appropriate only in limited circumstances, none of which appear to apply to you. As a result, your use of proportionate consolidation appears to represent the use of a tailored accounting principle. Revise your presentation to remove revenue recognized based on the use of proportionate consolidation. See FASB ASC paragraphs 323-10-45-1 and 810-10-45-14 and C&DI Question 100.04. |
Response to SEC Comment 1:
In future filings, the Partnership will revise its presentation to remove revenue recognized based on the use of proportionate consolidation.
* * * * *
We appreciate the opportunity to respond to the comment provided.
Sincerely,
/s/ Scott Gayton
Scott Gayton
Chief Financial Officer, Teekay Gas Group Ltd.
(Principal Financial and Accounting Officer)
| cc: | Alan Semple (Audit Committee Chair) |
David Matheson (Perkins Coie LLP)
Philippa Wilshaw (KPMG LLP)
