US Sales of a Korean Corp - Federal Tax Impact

August 29, 2025

As global e-commerce platforms and cross-border corporate structures become increasingly intertwined, foreign enterprises face complex questions about U.S. tax exposure. This article examines the federal income tax implications for a Republic of Korea corporation that sells consumer products in the United States through two distinct channels: (1) by leveraging Amazon’s fulfillment infrastructure, which includes warehousing and shipping services within the U.S., and (2) through a wholly owned Delaware subsidiary with a physical office in New York City. The central inquiry is whether—and to what extent—the Korean parent corporation itself incurs U.S. federal income tax obligations under domestic law and the U.S.–Korea income tax treaty.

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