Can my Korean parent charge my US subsidiary at cost for shared back-office work? Yes — if the service fits the services cost method (SCM) safe harbor in Treasury Regulation §1.482-9(b). SCM lets a Korean parent bill routine support services (bookkeeping, HR administration, payroll, IT help desk, legal admin) to a US sub at pure…
Does OBBBA change the charitable deduction in 2026? Yes. Starting with the 2026 tax year, a new 0.5%-of-AGI floor and a 2/37ths cap on itemized deductions reduce the charitable deduction for most itemizers, but a new $2,000 above-the-line deduction and qualified charitable distributions give donors ways around them. Every November, a client calls our Los…
Are IRS partnership audits really going away? Treasury performance data show partnership examination starts fell about 76% from fiscal year 2023 to fiscal year 2025, but IRS partnership audits are still live for the biggest partnerships, and the Bipartisan Budget Act regime still bills the partnership itself when one lands. A client calls after reading…
Will the IRS send an automatic adoption credit refund? Yes, in many cases. In October 2026 the IRS began issuing an adoption credit refund to taxpayers who carried unused adoption credit forward from 2020–2024. No amended return is required for most eligible families. For many adoptive families, the adoption tax credit is the single largest…
Is my IRA and 401(k) withdrawal taxable in Korea, in the US, or both? As a US citizen, your IRA 401k Korea withdrawal is always subject to US tax on your Form 1040, no matter where you live. Korea may also tax it under its worldwide-income rules — the US–Korea tax treaty and the foreign…
What are the new premium tax credit rules under OBBBA? The IRS and Treasury have issued proposed regulations (REG-101576-26) implementing H.R. 1 changes to Section 36B — the premium tax credit. The dollar cap on repayment of excess advance credits is gone starting with 2026 returns, new marketplace verification rules kick in after 2027, and…
When does the SEC require pro forma financial information? Regulation S-X Article 11 requires it for significant business acquisitions, dispositions, spinoffs, and other transactions where the illustration would be material to investors. The 2020 amendments reorganized pro forma financial information around three adjustment categories, and the columnar totals now stop at transaction accounting and autonomous…
Can a stablecoin be a cash equivalent under US GAAP? FASB’s August 2026 proposed Accounting Standards Update under Topic 230 says yes — but only when three attributes line up. The Master Glossary definition does not change. Stablecoin cash equivalents and a new disclosure of the significant components of cash equivalents are now on the…
What should a Korean company check before choosing a US CPA firm? Check five things: which state licenses the CPA and whether the license is active, whether the firm also handles the Korea-side work (overseas direct investment reporting and the parent’s reporting package), whether the same team carries the work from setup into monthly books…
Our US-incorporated startup wants Korean TIPS funding — can we just drop a Korean subsidiary under our Delaware C-Corp, or do we actually need to reverse flip to a Korean top? Dropping a Korean subsidiary does not qualify the group for Korean TIPS: the Korea Technology Finance Corporation and the operator programs run the grant…
Does SB 253 November 10 apply to my company? California’s Climate Corporate Data Accountability Act requires US entities with annual revenue over $1 billion that do business in California to report scope 1 and scope 2 greenhouse gas emissions to the California Air Resources Board. CARB has proposed to move the first report from August…
What is the Subchapter V debt limit in 2026? About $3.4 million in aggregate noncontingent, liquidated secured and unsecured debt. The temporary $7.5 million cap expired on June 21, 2024 and has not yet been restored. The subchapter v debt limit is set by 11 U.S.C. § 1182, with pending legislation that would make the…
What is FPI status, and does your company qualify? Foreign Private Issuer status is an SEC classification in Rule 405 and Rule 3b-4 that lets a qualifying non-US company report on Form 20-F, skip Form 10-Q, and use IFRS without a US GAAP reconciliation. A June 2025 SEC concept release may change the eligibility rules…
How do I open a US business bank account from Korea without an SSN or ITIN? After an EIN comes in, a US business bank account is the first real spending tool for the entity, and in 2026 a non-resident founder can realistically open one online in one to three weeks with the right documents…
Is student loan forgiveness taxable again in 2026? For most federal borrowers, yes. The temporary student loan forgiveness exclusion added by the American Rescue Plan Act sunset on December 31, 2025. Discharges in 2026 are generally includible in income under Internal Revenue Code §108, unless Public Service Loan Forgiveness, insolvency, or another specific exclusion applies….
What do California’s new AI workplace laws require? Three bills — AB 1883, SB 951, and SB 947 — take effect January 1, 2027. The California AI workplace laws ban AI-powered emotion and neural monitoring, add technology-displacement disclosures to WARN Act notices, and require a human to review any AI-driven discipline or termination before it…
Can a crypto staking trust still qualify as a grantor trust in 2026? Yes — if it meets the fourteen conditions in IRS Rev. Proc. 2026-20. The new revenue procedure gives a crypto staking trust a safe harbor to stake its digital assets without losing investment-trust status under 26 CFR 301.7701-4(c). Every quarter we hear…
The California Franchise Tax Board’s monthly tax news for October 2026 lands at the right moment for owners of businesses that file in California: there is a federal conformity cleanup bill to pencil into 2025 returns, new 2026 indexed amounts for personal returns, and a reminder on the Form 100 extended due date now a…
International tax moved in four places business owners should flag this week: the OECD put out a refreshed Model Tax Convention with a new remote-work permanent establishment framework, France filed its 2027 budget bill, South Africa opened consultation on a digital VAT architecture, and Singapore extended its innovation incentive to artificial intelligence adoption. What changed…
State and local tax moves this week give business owners concrete tasks for the fourth quarter: a Washington DC conformity bill that forces federal-to-state add-backs, a Rhode Island amnesty window, a California cash-rounding law and a California conformity bill that changes who counts as a covered employee for the executive-pay deduction limit. What changed this…
Four federal tax developments landed in the last stretch of this session of Congress that owners of small and mid-sized businesses should be aware of. Here is what moved, who it affects, and what to do. What changed this week Development Who it affects Senate passes the Taxpayer Assistance and Service Act (H.R. 5349) Any…
How much does US business formation cost in 2026? For a one-person company, state filing fees in 2026 range from about $100 (Wyoming, Florida) to $425+ (New York with publication). The us business formation cost you actually pay in Year 1, however, is driven more by annual state taxes and the registered agent than by…
Who claims the educator expense deduction, and did pre-K get added? The educator expense deduction is a $300 above-the-line adjustment under IRC §62(a)(2)(D) for teachers, aides, counselors, principals, and instructors. Congress has moved to extend it to pre-K and early childhood educators through H.R. 5334, the SEED Act. Every spring, teachers walk into our Los…
Can you capitalize AI software costs under US GAAP? Sometimes. US GAAP has no AI-specific rule — the existing internal-use software guidance in ASC 350-40 still controls. If AI software costs are project-specific, measurable, and incurred after the application development stage begins, they may be capitalized. General-purpose AI subscriptions are expensed. Every quarter our Los…
How does ASU 2026-03 change investment company fair value? It requires an investment company to apply a discount when a contractual sale restriction prevents it from selling an equity security on the measurement date. The amendment is scoped to investment companies and to equity securities only, is effective for annual periods beginning after December 15,…
W-8BEN vs W-9 at a Korean bank — which form do I file? If you are a US citizen or green-card holder, you file W-9; if you are a non-US Korean national with the account, you file W-8BEN. The form proves your US tax status under FATCA and lets Korean brokers apply the right US…
Did IRS First Time Abate help you — or cost you? Sometimes it does both. First Time Abate often removes an IRS penalty before anyone at the IRS has decided whether your reasonable cause story was good enough. The penalty disappears, the file looks closed, and a safety net you may need in the next…
Do I owe tax when I’m paid to care for a family member? Usually, yes — the caregiver tax picture turns on whether the caregiver is an employee of the family or self-employed, whether the money qualifies as a Medicaid waiver payment, and whether the family has to file Schedule H and issue a Form…
Does the Section 351 ETF conversion still work after Rev. Rul. 2026-20? Not the way it has been sold. The IRS now treats a planned transfer of securities to a new ETF followed by an authorized-participant redemption of those same securities as a single taxable exchange, not a tax-free diversification. The Section 351 ETF conversion…
If my Korean parent only wants to watch the US market, is a representative office enough — or do I already need a branch? A US representative office that limits itself to market research, information gathering, and liaison work typically falls outside the US “trade or business” definition under IRC §864(b), so it files no…
