Interpretive Response : If registrants and their independent accountants believe that the institutional and economic environment in Japan with respect to the registrant is sufficiently different that . accounting principles for stock dividends should not apply to free distributions, the staff will not object to such distributions being accounted for at par value in accordance with Japanese practice. If such financial statements are identified as being prepared in accordance with . GAAP, then there should be footnote disclosure of the method being used which indicates that . companies issuing shares in comparable amounts would be required to account for them as stock dividends, and including in such disclosure the fair value of any such shares issued during the year and the cumulative amount (either in an aggregate figure or a listing of the amounts by year) of the fair value of shares issued over time.