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

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.

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.