For more information on the IFA USA Branch 2008 Annual Conference, please visit the conference site.
Friday, February 29, 9:30 AM - International Tax Issues Associated with World Class Entertainers and Athletes
Paul A. Sczudlo, Loeb & Loeb LLP
Alan J. Epstein, Jackoway Tyerman Wertheimer Austen Mandelbaum & Morris
Mark Williams, The Walt Disney Company
Hollywood is home to the film business. The “biz” has truly been one of the United States’ most global industries for generations. That remains true today and is increasingly the case for the entertainment and sports industries generally. Those industries are built on the cult of the personality: Whether a famous actor, ballplayer, novelist, rock star or ballerina, individuals’ services are a unique and critical element. Cross-border tax planning for the services of talent is critical for entertainers’ and athletes’ participation in events, productions, licensing and distribution activities and competitions that may involve numerous countries. This panel will explore the tax issues raised for talent and sports figures from their perspectives and the perspectives of the producers, events organizers, teams and others engaging, sponsoring or promoting them. Among other issues, the panel will consider the cross-border use of personal service companies (“loan-out companies”), the determination of source for income earned by talent, tax withholding issues, the application of tax treaties’ entertainers and sportsmen articles, foreign tax credit planning, key state, provincial and local tax issues, and structuring issues and practices in Canada, the United Kingdom and several other significant jurisdictions.