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…
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…
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…
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…
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…
How does crypto international tax structuring work for a global group? A US-founded crypto business has to align entity classification, controlled-foreign-corporation rules, transfer pricing, IP ownership, and digital-asset reporting with how it actually operates. Crypto international tax is not a jurisdiction search; it is a documentation discipline. A protocol launches with founders in Los Angeles,…
Does the US-Korea tax treaty actually reduce the 30% default withholding on a software royalty paid to a Korean licensor? Yes — a US payer must generally withhold 30% on a US-source royalty, but the Korea tax treaty royalty article can cut the rate to 10% or 15% depending on the royalty type, provided the…
This international tax update covers three moves that reach owners of US businesses with any cross-border footprint. Australia has released an exposure draft that would reshape its Research and Development Tax Incentive from mid-2028; Hong Kong has unveiled tax-related measures in the 2026 Policy Address; and the OECD has published its 2026 report on tax…
How much U.S. corporate tax will my company actually pay in 2026? A U.S. C corporation pays a flat 21% federal corporate income tax under Internal Revenue Code §11(b), plus a state corporate income tax that ranges from 0% (Wyoming, Nevada, South Dakota) up to about 11.5% (New Jersey, at the top surtax bracket) depending…
Do my Korean bank accounts really need to be reported on FBAR? Yes — any U.S. person whose foreign financial accounts (including Toss, KakaoBank, KEB Hana, Kookmin, or a Korean brokerage) together exceed $10,000 at any point during the calendar year must file FinCEN Form 114. The $10,000 test is measured across all accounts combined,…
Are ICE Endex futures Section 1256 contracts now? Yes — for contracts entered into on or after September 1, 2026. In Rev. Rul. 2026-16, the IRS determined that ICE Endex, a Netherlands regulated exchange, is a qualified board or exchange under § 1256(g)(7)(C), so its futures and futures options get mark-to-market and 60/40 capital-gain treatment…
What changed for FIRPTA in 2026 for foreign investors in U.S. real estate? Two Treasury releases moved the ground under cross-border deals — the 2025 proposed regulations on domestically controlled REITs repeal the lookthrough rule for U.S. corporate shareholders, and the 2025 final FIRPTA-adjacent Sec. 892 regulations give foreign governments a workable path to hold…
Can the IRS assess a Form 3520 penalty without going to court? Yes. In Zhang v. IRS (N.D. Cal., May 4, 2026), the court held that Internal Revenue Code section 6039F gives the IRS direct assessment authority for a late Form 3520, meaning the form 3520 penalty lands on your account first and you must…
Which global tax changes in 2026 affect my U.S. business? If you have a foreign parent, a foreign subsidiary or cross-border intragroup payments, four do: proposed U.S. foreign tax credit rules with a September 17 comment deadline, Pillar Two registration deadlines arriving jurisdiction by jurisdiction, spreading e-invoicing mandates, and sharply increased transfer pricing scrutiny. International…
What is the Coca-Cola transfer pricing case, and why should other US companies care? The Coca-Cola transfer pricing case is a dispute over how a US parent must price transactions with its foreign affiliates under IRC §482. The Tax Court sided with the IRS in 2020 and the appeal is now before the Eleventh Circuit…
How do foreign entities e-file 1042-S and 1099 forms after FIRE is retired? Through the new IRS Foreign Filer TCC Registration System. It gives foreign filers whose authorized users have no U.S. SSN or ITIN a way to obtain a Transmitter Control Code and transmit information returns electronically through IDES. The way U.S. information returns…
What were the key international tax developments in early-to-mid June 2026? The OECD pushed forward on the global minimum tax (Pillar Two) — releasing practical fixes to the GloBE Information Return (GIR) XML schema for first filings, an updated 2026 consolidated commentary, and new transfer-pricing guidance on intragroup services. In the EU, the Court of…
How is income from the 2026 FIFA World Cup taxed across the U.S., Canada, and Mexico? The 2026 FIFA World Cup is co-hosted by three countries, which raises a thorny question: when a national team earns prize money and other compensation, how is that income sourced among the United States, Canada, and Mexico? To avoid…
What is the foreign earned income exclusion relief under Rev. Proc. 2026-16? The IRS waives the section 911 residency and presence tests for 2025 for qualified individuals who had to leave seven specified countries due to war, civil unrest, or similar adverse conditions. If you’re a US citizen or resident who was living abroad and…
