This Note will focus on the major tax planning issues confronting entertainers and athletes (hereinafter collectively referred to as “performers” unless separately stated) who perform in the United States and around the world. This Note will first explore the United States rules that apply when there is no applicable treaty; then it will discuss the effect of typical treaty provisions on those basic rules and the optimal business structure by which a performer can maximize the benefits of a given treaty. In particular, the Note will examine the unfavorable provisions, from the performer’s point of view, of two bilateral tax treaties recently signed by the United States with the United Kingdom and Canada. Finally, relevant provisions of United States tax treaties with Australia, France, Germany and Italy are reviewed. The Note focuses on these nations because, along with the United States, they produce the greatest number of performers.
Theodore Delaney Weis,
Tax Planning Issues Affecting International Entertainers and Athletes,
9 Fordham Int'l L.J. 97
Available at: http://ir.lawnet.fordham.edu/ilj/vol9/iss1/3