About the Course
Introduction
This CLE/CPE webinar will provide tax counsel and planners with a comprehensive guide to tax planning challenges and opportunities for clients who have a tax presence in both the U.S. and South Korea. The panel will discuss tax law and treaty provisions that govern tax and fiduciary rules in both South Korea and the United States. The webinar will focus on the U.S. tax and other consequences for South Korean clients with a U.S. tax presence and U.S. taxpayers with South Korea-based assets.
Description
The U.S. and South Korea have significant economic and social ties, resulting in a constant flow of cross-border business transactions and citizens migrating between the two countries. Tax counsel and advisers must navigate challenges stemming from the interpretation and enforcement of U.S. and South Korea tax rules to avoid adverse tax liability from either country.
Among the most critical planning challenges is reconciling the U.S. and South Korea rules governing residence and domicile. South Korea has recently updated its residency rules and reporting requirements with some differences compared to U.S. rules, and even inadvertent failure to meet filing obligations due to a misapplication of these rules can be costly. U.S. tax advisers serving clients with a presence in the U.S. and South Korea will need to understand these rules to avoid costly tax and penalties.
Another critical planning element is avoiding dual taxation on income and gains. The U.S. and South Korea have a comprehensive tax treaty system that addresses most dual taxation concerns, but, as in all international planning, tax advisers must understand the particular provisions to avoid an unpleasant tax bill—or maybe two.
The interaction of these regimes—residency rules, treaty provisions, the saving clause, and relief mechanisms—creates both planning opportunities and compliance risks. Tax counsel must efficiently navigate these rules to minimize adverse tax liability from either country.
Listen as our experienced panel provides comprehensive and practical guidance on navigating U.S.-South Korea cross-border tax planning and reporting issues.
Presented By
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
Ms. Liu concentrates her practice in areas of domestic and international tax. She has served as lead or co-counsel in federal courts throughout the United States involving criminal tax matters, tax controversies, employment tax controversies, SEC securities litigation, and post-employment covenants not to compete (including the successful litigation in district court for the Northern District of Georgia proceeding of first impression adjudicating the enforceability of a forum select clause, and covenant not to compete controversy. This case was named in the California Labor and Employment Bulletin as one of the top ten California Trade Secrets and Unfair Competition Developments). Ms. Liu has successfully resolved hundreds of serious tax matters for business and high net worth individuals, both in court and through negotiations with the IRS. She has assisted many clients in tax controversy matters at audit and administrative appeals before the IRS and state tax authorities. Ms. Liu also has significant experience in representing clients before the IRS programs offered to taxpayers to correct their past non-compliance. She has represented many clients through the IRS voluntary disclosure program and Streamlined Filing Compliance Procedures.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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CPE credit is not available on recordings.
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BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Date + Time
- event
Tuesday, November 10, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. U.S.-South Korea income tax treaty overview and dual tax mitigation provisions
II. Domicile and residency rules
III. Passive and unearned income treatment
IV. U.S. tax reporting requirements for South Korea-sourced investments
V. Dual tax relief mechanisms
VI. Planning considerations
The panel will review these and other important topics:
- What are the tax treaty provisions for mitigating dual taxation on ownership of cross-border pass-through entities?
- Limitation of benefits clauses and provisions in the U.S.-South Korea income tax treaty
- Key risks and challenges of passive/unearned income in cross-border situations
- U.S. reporting requirements for South Korea-sourced investments
Learning Objectives
After completing this course, you will be able to:
- Recognize U.S. tax reporting requirements for U.S. taxpayers residing in South Korea
- Establish the domicile of the taxpayer and whether tax treaty benefits are available based upon the determined domicile
- Distinguish among the various tests used to determine whether a taxpayer is eligible for tax treaty benefits
- Identify opportunities to mitigate dual taxation
- Identify the limitations of benefits in the U.S.-South Korea tax treaty
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation, including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI/NCTI, Subpart F, and the related Section 250 deductions.
BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
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