US Corporate Tax Changes 2026: What Turkish Companies and Investors Need to Know

The US corporate tax landscape is undergoing significant changes in 2026. Several provisions of the 2017 Tax Cuts and Jobs Act (TCJA) are expiring or being modified, while new minimum tax rules and international provisions are reshaping the compliance obligations of foreign-owned US entities. For Turkish companies operating in or investing into the United States, understanding these shifts is essential for effective tax planning this year.

The TCJA introduced a flat 21% corporate tax rate, which remains in place. However, several related provisions are changing:

• Bonus depreciation: The 100% first-year bonus depreciation that allowed immediate expensing of qualified property has been phasing down. In 2026, it drops to 20% before potentially expiring entirely. Turkish companies that have been relying on this provision for capital investment planning must reassess their depreciation strategies.
• Section 163(j) interest deduction limitation: The calculation base reverts to EBIT (earnings before interest and taxes) rather than EBITDA, making the limitation more restrictive. Highly leveraged Turkish subsidiaries in the US will feel this change acutely.
• R&D expensing: The requirement to capitalize and amortize domestic R&D costs over five years (15 years for foreign research) continues. Turkish tech companies with US R&D operations should review their cost allocation structures.

The Inflation Reduction Act introduced a 15% Corporate Alternative Minimum Tax on the adjusted financial statement income of large corporations. In 2026, IRS guidance on CAMT has become more detailed, affecting:

• US subsidiaries of Turkish parent companies with consolidated global revenues exceeding $1 billion
• Applicable financial statement income calculations that may differ significantly from taxable income
• Foreign tax credit utilization under the CAMT framework

Global Intangible Low-Taxed Income (GILTI): Turkish parent companies with US subsidiaries that generate intangible income should monitor GILTI high-tax exclusion elections. The effective GILTI rate and the interaction with Pillar Two rules create complex planning opportunities.

Base Erosion and Anti-Abuse Tax (BEAT): Turkish companies making deductible payments to related foreign parties from their US operations remain subject to BEAT. The 10% rate (12.5% for certain taxpayers) applies to base erosion payments exceeding the threshold.

While the US has not enacted domestic Pillar Two legislation, Turkish parent companies subject to Pillar Two in Turkey or other jurisdictions must consider how US tax positions affect their global minimum tax calculations. The OECD's qualified domestic minimum top-up tax (QDMTT) framework and its interaction with US taxes is a key planning area for 2026.

Beyond federal changes, Turkish companies should be aware of:

• New York State: Continues to impose its own corporate franchise tax with apportionment rules that can significantly affect effective rates for NYC-based operations
• Combined reporting: Several states have expanded combined reporting requirements that can pull Turkish parent entities into state tax filings
• Sales tax nexus: Economic nexus thresholds established post-Wayfair continue to evolve, affecting Turkish companies selling goods or services into US states

The IRS has significantly increased transfer pricing enforcement resources. Turkish companies with intercompany transactions — including management fees, royalties, loans, and cost-sharing arrangements — should ensure their documentation is current and defensible under the arm's length standard. The IRS's Large Business & International (LB&I) division has specific campaigns targeting:

• Related-party transactions with treaty countries
• Cost-sharing arrangement buy-in payments
• Inbound distributors with thin margins

1. Review depreciation schedules: Assess the impact of reduced bonus depreciation on capital expenditure plans
2. Model interest deduction limitations: Recalculate Section 163(j) limitations under the EBIT base
3. CAMT applicability analysis: Determine whether your US entity or consolidated group crosses the $1 billion threshold
4. Transfer pricing documentation update: Ensure contemporaneous documentation is in place before filing season
5. State nexus review: Confirm which states require filings based on economic activity
6. Pillar Two coordination: If your Turkish parent is subject to Pillar Two, coordinate US and global tax positions

Our tax attorneys work closely with Turkish companies navigating the intersection of US federal, state, and international tax obligations. Whether you need a comprehensive tax position review, transfer pricing documentation, or guidance on structuring US investments tax-efficiently, our team provides practical counsel tailored to Turkish-American business relationships.

This article is for informational purposes only and does not constitute legal or tax advice. Please consult qualified counsel for advice specific to your situation.