On the Ground with International Tax Reform: It’s Time to Start Thinking About How the OECD Two Pillar Solution Could Affect Your Business

Robert Freedlander, Director of Finance, Fluor Corporation
Mike Louis, Tax Counsel, Fluor Corporation

The world is increasingly interconnected, but interconnectedness does not mean free of obstacles. A container ship snared in the sandy bottom of the Suez Canal can disrupt the availability of clothing, electronics, and heavy machinery on the other side of the world. As the Suez saga unfolded the world watched, captivated by the sensational nature of the story, the disruption it was causing, and how unlikely such an event seemed to be. Technological advancements in transportation and communication have largely conquered the traditional physical obstacles to trade. Rugged mountain passes, rough seas, and vast distances are no longer the impediments they once were. Instead, the most onerous obstacles facing modern commerce are human creations—the quagmire of rules and regulations that inundate every industry in every corner of the world. The Port of Los Angeles container ship bottleneck is one current example. A local zoning ordinance restricting (for aesthetic reasons) the stacking height of empty containers was cited as contributing to the congestion. Local officials suspended enforcement to hopefully alleviate pressure at the port. Now, more than any prior time in human history, we are our own greatest obstacle. In a landscape of self-inflicted complexity, international tax is a particularly treacherous path, and there is no excavator large enough or tugboat powerful enough to painlessly free an unwary enterprise grounded on the uncompromising banks of an international tax dilemma. Changes to these rules are on the horizon, and taxpayers need to be prepared.

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Taxation Engineering December 2021 Vol.14, No. 57, Autumn 2021

Robert Freedlander

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Rob Freedlander is Director of Expat Accounting & Financial Compliance for Fluor Enterprises Inc. He deals with regulatory authorities across the globe either directly or through engaged accounting firms and law firms. Rob holds an undergraduate degree from Northwestern University, a graduate degree in Finance from Boston University and completed an executive management program at Stanford University.

Mike Louis

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Fluor Corporation (NYSE: FLR) builds a better world by applying world-class expertise to solve its clients' greatest challenges. Fluor's 44,000 employees provide professional and technical solutions that deliver safe, well-executed, capital-efficient projects to clients globally. Fluor, a Fortune 500 company, is headquartered in Irving, Texas and has been providing engineering, procurement, and construction services for more than 100 years.

Taxation Engineering December 2021 Vol.14, No. 57, Autumn 2021