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United States securities and exchange commission logo
September 27, 2022
Ira Birns
Executive Vice President and Chief Financial Officer
World Fuel Services Corporation
9800 N.W. 41st Street
Miami FL 33178
Re: World Fuel Services
Corporation
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed February 25,
2022
File No. 001-09533
Dear Mr. Birns:
We have limited our review of your filing 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.
Form 10-K for the Fiscal Year Ended December 31 2021
Management s Discussion and Analysis of Financial Condition and
Results of Operations
Reportable Segments
Results of Operations, page 24
1. Please revise your
discussion to describe and quantify how inflation has affected your
costs and margins,
explaining the relative effect of each. Refer to Item 303 of Regulation
S-K and Section III.B.4
of Release No. 33-8350 for guidance.
Liquidity and Capital Resources
Cash Flows
Operating Activities, page 29
2. Your analysis of
changes in operating cash flows references working capital, operating
results, and higher
fuel prices. Note that references to working capital and operating
Ira Birns
World Fuel Services Corporation
September 27, 2022
Page 2
results may not provide a sufficient basis to understand how operating
cash actually was
affected between periods. Your analysis should discuss factors that
actually affected
operating cash and reasons underlying these factors. Refer to the
introductory paragraph
of section IV.B and paragraph B.1 of Release No. 33-8350 for guidance,
and section
501.04 of the staff s Codification of Financial Reporting Releases
regarding quantification
of variance factors. Please revise your disclosure as appropriate.
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 Patrick Kuhn at (202) 551-3308 or Amy Geddes at (202)
551-3304 with
any questions.
FirstName LastNameIra Birns Sincerely,
Comapany NameWorld Fuel Services Corporation
Division of
Corporation Finance
September 27, 2022 Page 2 Office of Trade &
Services
FirstName LastName