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United States securities and exchange commission logo





                            December 29, 2021

       Phil Lister
       Chief Financial Officer
       Huntsman CORP
       10003 Woodloch Forest Dr.
       The Woodlands, TX 77380

                                                        Re: Huntsman
Corporation
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 12,
2021
                                                            File No. 333-85141
                                                            Huntsman
International LLC
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 12,
2021
                                                            File No. 001-32427

       Dear Mr. Lister:

              We have limited our review of your filings to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Huntsman Corporation Form 10-K for the Fiscal Year Ended December 31,
2020

       Item 7. Management's Discussion and Analysis of financial Condition and
Results of Operations
       Outlook, page 30

   1.                                                   Please address the
following regarding your presentation of adjusted tax rate:
                                                            At the bottom of
page 30, you present adjusted effective tax rate as 19% without
                                                            presenting the
actual effective rate or providing a reconciliation. Please revise
                                                            accordingly to
comply with Item 10(e).
                                                            You also disclose
that your forecasted adjusted effective tax rate for 201 is expected
                                                            to be approximately
22% to 24%. We note your disclosure on page 35 that you are
                                                            unable to provide
accurate calculations or estimations of reconciling items. Tell us
 Phil Lister
Huntsman CORP
December 29, 2021
Page 2
              how you determined it was appropriate to present the forecasted
adjusted effective
              tax rate without presenting the forecasted actual effective tax
rate for the period in
              question. Further, tell us how you determined your presentation
was appropriate if
              you are unable to provide accurate calculations or estimations of
the reconciling
              items.
Notes to Consolidated Financial Statements
Note 27. Operating Segment Information, page F-61

2.       Your presentation of Total Segment Adjusted EBITDA does not comply
with ASC 280-
         10-50-30(b) as the inclusion of 'Corporate and other' does not
represent the total of the
         reportable segments' measure of profit or loss. As such, Total Segment
Adjusted EBITDA
         would represent a non-GAAP measure which is specifically prohibited in
your financial
         statement footnotes by Item 10(e)(1)(ii)(c) of Regulation S-K.
Furthermore, the total of
         your reportable segments' measure of profit or loss should be
reconciled to consolidated
         net income/(loss) before income taxes. Accordingly, please revise your
presentation of
         your reportable segments' measure of profit or loss and the
accompanying reconciliations
         as well as your discussion of Non-GAAP Financial Measures on page 34.
This applies to
         your Form 10-Q for the quarter ended September 30, 2021 and your press
release
         furnished as exhibit 99.1 to your Form 8-K filed October 29, 2021 as
well.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at
202-551-3494 with
any questions.



FirstName LastNamePhil Lister                                   Sincerely,
Comapany NameHuntsman CORP
                                                                Division of
Corporation Finance
December 29, 2021 Page 2                                        Office of Life
Sciences
FirstName LastName
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