• videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

U.S. Tax Issues and Compliance for Foreign Artists and Athletes

About the Course

Introduction

This CLE/CPE webinar will provide tax counsel and advisers guidance on various U.S. tax rules impacting foreign entertainers and athletes. The panel will discuss applicable U.S. tax law, residency requirements, withholding considerations, utilizing tax treaties, and other techniques to minimize tax liability for foreign entertainers and athletes performing or competing in the United States or those who are U.S.-based going abroad.

Description

U.S.-based or foreign entertainers and athletes travel abroad frequently to perform or compete within their given careers, potentially being subjected to various taxes. Proper tax planning can mitigate the jurisdictional taxes for a U.S.-based entertainer or athlete working outside the U.S. or a nonresident traveling to the U.S.

U.S. citizens, residents, and green card holders are taxed on worldwide income regardless of whether it was earned within the U.S. or outside its borders. However, nonresidents are taxed on income effectively connected with the U.S. This is pivotal to assessing applicable tax regimes and planning, and tax counsel must be able to differentiate between the two. Under certain circumstances, utilizing the right entity structure and other strategies can generate substantial tax savings; however, there are drawbacks and nuances that must be considered.

In addition to structuring and other tax planning strategies, there are special treaty benefits and exclusions available for nonresident performers who reside in treaty jurisdictions and central withholding agreements (CWAs) with the IRS that can aid in reducing the burden of withholding taxes. Furthermore, the One Big Beautiful Bill Act (OBBBA) added provisions directly impacting performing artists.

Listen as our panel of foreign taxation experts discusses determining U.S. residency status, strategies to save taxes, unique treaty benefits, and reduced withholding opportunities for U.S. entertainers and athletes working abroad and nonresidents with ties to the U.S.

Presented By

Kathleen Agbayani
Managing Director
KPMG US, LLP

Ms. Agbayani is Managing Director, Washington National Tax at KPMG US. 

Alberto F. Guzman, CPA, CRFAC, MST
Managing Partner
AbitOs, PLLC

Mr. Guzman leads a team that looks to him for his extensive knowledge of the intricacies of international tax codes and the complex accounting practices that need to be leveraged for multinational corporations doing business in the U.S. and high-net-worth individuals with an international lifestyle. With over twenty years of experience with local and international firms, he has extensive knowledge of financial and tax strategies for foreign investments into the U.S., cross-border business operations, and international, federal, and state taxation. Mr. Guzman's unique professional experience includes serving Latin American, Asian, and European companies. He is as highly respected for his expertise in international tax matters as he is with domestic tax situations and often advises domestic and foreign-based businesses and investors on their out-bound and in-bound ventures, with a particular focus on complying with, while at the same time, minimizing U.S. tax obligations.

Credit Information
  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, April 9, 2026

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Overview; applicable U.S. tax rules

II. Impact of the OBBBA

III. U.S. resident athletes and entertainers

IV. Nonresident athletes and entertainers

V. Structuring opportunities and considerations

VI. Tax treaty relief

VII. Withholding obligations

The panel will explain these and other critical issues:

  • U.S. residency tests and tax compliance
  • Benefits of special treaty exclusions and benefits for entertainers and athletes
  • Utilizing a central withholding agreement with the IRS as a withholding alternative
  • Steps to take to reduce the effective tax rate for entertainers and athletes
  • Provisions in OBBBA impacting entertainers and athletes
  • Withstanding potential IRS examinations