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…
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…
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…
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…
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…
Are foreign athletes at the 2026 FIFA World Cup subject to US taxes? Yes — the 2026 FIFA World Cup tax rules require that nonresident alien athletes and entertainers have 30% federal withholding applied to US-source income, with relief available through Central Withholding Agreements and applicable tax treaties. The 2026 FIFA World Cup is set…
