Q1 2026 Regulatory Roundup: Key Deadlines and Developments for Turkish-US Business
Q1 2026 brings a dense calendar of regulatory deadlines and new rule implementations affecting Turkish businesses and investors in the United States. This roundup covers the most critical developments across tax, immigration, corporate compliance, trade, and financial regulation.
Q1 2026 Regulatory Roundup: Key Deadlines and Developments for Turkish-US Business
The first quarter of 2026 is a critical period for Turkish companies and investors with US operations. Multiple regulatory deadlines converge, new rules take effect, and enforcement priorities shift. This roundup provides a structured overview of the most important developments that Turkish businesses must address before March 31, 2026.
Tax Deadlines and Developments
January 15 — Q4 2025 Estimated Tax Payment
US corporations and individuals with US tax obligations must make their Q4 2025 estimated tax payment. Turkish individuals with US income and Turkish companies with US subsidiaries should confirm their estimated tax positions.
January 31 — W-2 and 1099 Filing Deadline
US employers must furnish W-2 forms to employees and 1099 forms to independent contractors. Turkish companies with US employees or contractors must comply.
March 15 — S-Corporation and Partnership Returns
S-corporations and partnerships (including LLCs taxed as partnerships) must file their federal tax returns or request extensions. Many Turkish-owned US entities use pass-through structures.
March 31 — Electronic Information Returns
Deadline for electronic filing of certain information returns, including 1099 series forms filed with the IRS.
Key Tax Development: Bonus Depreciation Phase-Down
As of January 1, 2026, bonus depreciation drops to 20% (from 40% in 2025). Turkish companies that planned capital expenditures expecting higher bonus depreciation should reassess their 2026 investment timing.
Corporate Compliance
FinCEN BOI Reporting — Ongoing Enforcement
FinCEN's beneficial ownership information reporting under the Corporate Transparency Act is in active enforcement. Turkish-owned entities that have not filed are accumulating daily civil penalties. Immediate filing is strongly recommended.
New York LLC Transparency Act — Compliance Verification
New York LLCs must ensure their beneficial ownership disclosures are current. The New York Department of State has begun processing filings and issuing compliance notices.
Delaware Annual Franchise Tax — March 1
Delaware corporations must pay their annual franchise tax by March 1, 2026. The franchise tax is calculated based on authorized shares or assumed par value capital, whichever is lower. Many Turkish companies use Delaware corporations as US holding entities.
Immigration Deadlines
H-1B Electronic Registration — Opens Early March
USCIS will open the FY2027 H-1B electronic registration window in early March 2026. Employers sponsoring Turkish nationals for H-1B status must register during this window. Missing the registration window means waiting until FY2028.
PERM Labor Certification Processing
The Department of Labor's PERM labor certification processing times continue to affect employment-based green card timelines. Turkish nationals in EB-2 and EB-3 categories should review their priority dates and consider premium processing options where available.
TN Visa Renewals
Turkish nationals working in the US under TN status (available to Canadian and Mexican citizens under USMCA) are not eligible for TN visas. However, Turkish professionals in the US on other work visas should review their status expiration dates and initiate renewal or extension proceedings.
Trade and Sanctions
OFAC Compliance — Ongoing Obligations
Turkish companies with US operations must maintain current OFAC sanctions compliance programs. OFAC has continued to update its Specially Designated Nationals (SDN) list, and Turkish companies with business relationships in sanctioned regions must ensure their screening programs are current.
Export Controls — EAR Compliance
The Bureau of Industry and Security (BIS) continues to update the Entity List and expand export control requirements. Turkish companies involved in technology transfer to or from the US must review their Export Administration Regulations (EAR) compliance programs.
Section 301 Tariffs — Ongoing Impact
Section 301 tariffs on Chinese goods continue to affect supply chains. Turkish companies that source components from China for US operations should review their tariff classification and consider first-sale valuation strategies.
Financial Regulation
FBAR Filing — April 15 (Extended to October 15)
US persons (including Turkish nationals who are US tax residents) with foreign financial accounts exceeding $10,000 must file FinCEN Form 114 (FBAR). The deadline is April 15 with an automatic extension to October 15.
FATCA Reporting
Foreign financial institutions, including Turkish banks with US account holders, must comply with FATCA reporting requirements. Turkish individuals with US financial accounts should ensure their US tax compliance is current.
SEC Reporting — Quarterly Filings
Turkish companies with US-listed securities must file quarterly reports (Form 10-Q) within 40–45 days of quarter end. Q4 2025 annual reports (Form 10-K) are due within 60–90 days of fiscal year end.
Real Estate
FIRPTA Withholding — Ongoing
Buyers of US real property from foreign sellers must withhold 15% of the purchase price under FIRPTA. Turkish sellers of US real property should plan for withholding and consider applying for withholding certificates to reduce or eliminate withholding.
NYC Real Property Income and Expense (RPIE) — May 1
Owners of income-producing NYC real property with an assessed value over $40,000 must file RPIE statements by May 1. Turkish investors with NYC income property must comply.
Employment Law
New York Minimum Wage Increase — January 1
New York's minimum wage increased on January 1, 2026. Turkish companies with New York employees must ensure their payroll systems reflect the updated minimum wage.
NYC Salary Transparency Law — Ongoing
New York City's salary transparency law requires employers to include salary ranges in job postings. Turkish companies hiring in NYC must comply with posting requirements.
Non-Compete Enforceability — Evolving Landscape
Following the FTC's non-compete rule litigation, the enforceability of non-compete agreements varies by state. Turkish companies with US employees should review their non-compete agreements for enforceability under applicable state law.
Looking Ahead to Q2 2026
Key Q2 2026 deadlines to begin preparing for:
- April 15: Individual federal tax returns (or extension requests)
- April 15: FBAR filing deadline (automatic extension to October 15)
- May 1: NYC RPIE filings
- June 30: H-1B petition filing deadline for FY2027 selected registrants
How ULF New York Can Help
Our attorneys monitor the regulatory landscape affecting Turkish-US business relationships and provide timely guidance on compliance obligations. Whether you need assistance with a specific deadline or a comprehensive compliance review, our team is available to help.
This article is for informational purposes only and does not constitute legal advice. Regulatory requirements are subject to change; please consult qualified counsel for current obligations specific to your situation.
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Written by
ULF New York Editorial Team
ULF New York legal team — New York-based attorneys advising Turkish companies and investors on U.S. market entry, corporate law, real estate, and international trade.