Law 433 - Income Taxation of Entertainers, Athletes, and Artists
J.D. University of California, Los Angeles, 1969
This course will focus on income tax issues of particular interest to lawyers who represent talent, especially issues that lurk in the shadows of what appear to be very ordinary entertainment industry transactions. Many of the topics to be covered are unique to entertainers, athletes and artists (or at least more commonly-confronted by them than by those who earn their livings in other industries), including: the use of loan-out corporations; the tax treatment of deferred and contingent compensation; the taxation of foreign source income; the tax classification of aliens; tax treaties that eliminate the double-taxation (i.e., taxation of the same income by two countries) of some types of income; and remedies available to entertainers, athletes and artists whose income is subject to double-taxation. Many entertainers, athletes and artists earn income in what are, for them, "foreign" countries, so in addition to covering the taxation of Americans by the United States, the course also will cover the taxation of foreigners by the United States, and the taxation Americans by foreign countries.