United States securities and exchange commission logo
October 3, 2023
Alex Peng
Chief Financial Officer
TAL Education Group
5/F, Tower B, Heying Center
Xiaoying West Street, Haidian District
Beijing 100085
People s Republic of China
Re: TAL Education Group
Form 20-F for the
Fiscal Year Ended February 28, 2023
Response dated
September 15, 2023
File No. 001-34900
Dear Alex Peng:
We have reviewed your September 15, 2023 response to our comment
letter and have the
following comment.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our September 7, 2023
letter.
Form 20-F for the Fiscal Year Ended February 28, 2023
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 140
1. We note from your
response to comment 3 that all of your "consolidated foreign operating
entities that use
variable interest entities or similar structures are incorporated or otherwise
organized in the PRC."
It appears from disclosures in your Form 20-F that you have at
least one subsidiary in
Hong Kong. Please confirm our assumption, if true, that your
reference to
"consolidated foreign operating entities that use variable interest entities or
similar structures [and
that] are incoporated or otherwise organized in the PRC" includes
any subsidiaries
organized or incorporated in Hong Kong. Otherwise, please
supplementally clarify
the jurisdictions in which your consolidated foreign operating
entities are organized
or incorporated and confirm, if true, that you have disclosed the
percentage of your
shares or the shares of your consolidated operating entities owned by
Alex Peng
TAL Education Group
October 3, 2023
Page 2
governmental entities in each foreign jursidiction in which you have
consolidated
operating entities.
Please contact Jennifer Thompson at 202-551-3737 with any questions.
Sincerely,
FirstName LastNameAlex Peng
Division of
Corporation Finance
Comapany NameTAL Education Group
Disclosure Review
Program
October 3, 2023 Page 2
cc: Yi Gao, Esq.
FirstName LastName