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Fundamental Issues In U.S. Taxation of Foreign Entertainers and Athletes
This article is Part One of a two-part article. Part Two will appear in our July 2016 issue.
The United States taxes its citizens and resident aliens on their worldwide income; nonresident aliens are taxed on their U.S. source income and income that is effectively connected with a trade or business in the U.S. These seemingly simple terms ' “citizen,” “resident,” “nonresident,” “U.S. source,” “effectively connected with a trade or business in the U.S.” (well, this last term doesn't seem so simple) ' have spawned volumes of regulations, rulings, cases and articles, the essence of all of which is to determine who is subject to tax in the U.S., and on what.
Layer on top of this the impact of income tax treaties, estate taxes, estate tax treaties and state taxes, and you have an exceedingly complex patchwork of rules to navigate. This article introduces the U.S. federal income tax issues.
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