The second half of 2026 brings a dense calendar of U.S. legal and regulatory developments with direct implications for Turkish companies and international investors. This Legal Watch summarizes the most significant items to monitor, organized by practice area.

This is a living document — ULF New York will update its analysis as developments unfold. Clients and subscribers are encouraged to contact us for guidance on any item that affects their specific business or investment activities.

The CTA's beneficial ownership reporting requirements remain subject to ongoing litigation. The Supreme Court is expected to address the constitutional questions raised by lower court decisions in its October 2026 term. International businesses with U.S. entities should monitor this litigation closely and be prepared to file reports promptly if enforcement is reinstated.

Action required: Maintain beneficial ownership information in a format ready for immediate filing. Do not assume that current litigation stays will continue indefinitely.

The Delaware General Corporation Law is expected to be amended in the 2026 legislative session to address several issues arising from recent court decisions, including the standards for stockholder approval of interested party transactions and the scope of director fiduciary duties in the context of controlling stockholder transactions.

Action required: Turkish companies with Delaware entities should review their governance documents and shareholder agreements against the anticipated amendments.

The U.S. Trade Representative (USTR) is conducting statutory four-year reviews of Section 301 tariffs on Chinese goods. The outcome of these reviews — which could result in tariff increases, decreases, or modifications — will affect supply chains that include Chinese components or manufacturing.

Action required: Turkish companies with supply chains that include Chinese-origin goods should monitor the USTR review process and model the impact of potential tariff changes on their cost structures.

The Bureau of Industry and Security (BIS) is expected to publish final rules implementing several export control reforms in H2 2026, including updates to the Entity List, modifications to license exception eligibility, and new controls on emerging technologies.

Action required: Turkish exporters of technology products, defense-related goods, and dual-use items should review their export compliance programs against the anticipated BIS rule changes.

The U.S.-Turkey bilateral trade relationship continues to evolve. Turkish companies should monitor developments in the following areas:

• Generalized System of Preferences (GSP): Turkey's GSP eligibility status and the impact of any changes on tariff rates for Turkish exports to the United States
• Defense trade: The status of Turkish defense industry companies on U.S. export control lists and the implications for defense-related transactions
• Investment treaty: The current status of U.S.-Turkey investment treaty negotiations and the implications for investor-state dispute resolution

New York City's "City of Yes for Economic Opportunity" zoning text amendment — which expands permitted commercial and light industrial uses in residential and mixed-use zones — is expected to be finalized in H2 2026. The amendment will create new development and conversion opportunities for investors in New York City real estate.

Action required: Turkish investors in New York City real estate should review the amendment's provisions against their existing and prospective holdings to identify new use opportunities.

New York State has significantly enhanced enforcement of wage theft laws in the construction industry. General contractors and developers — including foreign investors who engage construction contractors — face increased liability for wage theft by subcontractors.

Action required: Turkish investors in New York construction projects should ensure their construction contracts include robust wage compliance representations and audit rights.

USCIS processing times for E-2 treaty investor visa applications have been extended significantly. Turkish investors planning to use the E-2 visa to establish or manage U.S. businesses should plan for processing times of six to twelve months and consider premium processing where available.

Action required: Turkish investors planning E-2 applications should begin the process well in advance of their intended U.S. entry date.

The EB-5 Regional Center Program — which allows foreign investors to obtain U.S. permanent residency through qualifying investments in USCIS-designated regional centers — continues to process applications under the EB-5 Reform and Integrity Act of 2022. Turkish nationals are subject to the same priority date system as other nationalities; current processing times for Turkish applicants are significantly shorter than for nationals of oversubscribed countries.

Action required: Turkish investors considering EB-5 applications should consult with immigration counsel to assess current processing times and investment options.

The OECD's Pillar Two global minimum tax framework — which establishes a 15% minimum effective tax rate for large multinational enterprises — is being implemented by an increasing number of jurisdictions. The United States has not yet enacted Pillar Two legislation, but Turkish companies with U.S. operations may be subject to Pillar Two top-up taxes in Turkey or other jurisdictions where they operate.

Action required: Turkish multinationals with U.S. operations should assess their Pillar Two exposure and model the impact of top-up taxes on their effective tax rates.

The IRS has significantly increased its international enforcement activities, including audits of transfer pricing arrangements, foreign tax credit claims, and FBAR/FATCA compliance. Turkish companies with U.S. subsidiaries should ensure their intercompany pricing arrangements are documented and defensible.

Action required: Review transfer pricing documentation for all intercompany transactions between Turkish parent companies and U.S. subsidiaries.

2026 marks the 65th anniversary of the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. The Convention remains the cornerstone of international commercial arbitration enforcement, with 172 contracting states. Both the United States and Turkey are parties.

Practical note: Turkish companies with U.S. commercial contracts should ensure their arbitration clauses specify a seat in a New York Convention contracting state to maximize enforceability of any resulting award.

The American Arbitration Association (AAA) and its international division (ICDR) are expected to publish updated arbitration rules in H2 2026. The amendments are expected to address AI-assisted arbitration procedures, expedited proceedings for mid-size disputes, and enhanced emergency arbitrator provisions.

Action required: Turkish companies with AAA/ICDR arbitration clauses in their U.S. contracts should review the updated rules when published and assess whether any amendments affect their existing agreements.

For guidance on any of the developments summarized in this Legal Watch, or for assistance with U.S. market entry, cross-border transactions, or compliance matters, contact ULF New York:

New York Office: Rockefeller Center, 1270 Avenue of the Americas, 20th Floor, New York, NY 10020 Istanbul Office: Maslak Giz 2000 Plaza, Istanbul Email: [email protected] Phone: +1 (646) 421-9966