Interested in training for your team? Click here to learn more

International Tax Issues for Athletes and Entertainers: Residency, Tax Treaty Provisions, Mitigating Dual Taxation

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, August 20, 2020

Recorded event now available

or call 1-800-926-7926

This course will discuss ways to mitigate the tax burden for foreign athletes and entertainers. Our international taxation experts will discuss residency requirements along with structuring opportunities, tax treaty benefits, and withholding considerations for U.S. resident and nonresident performers.


Individuals increasingly travel abroad for work, and it is the nature of the business for many athletes and entertainers. Proper planning can mitigate the jurisdictional taxes for an American-based performer 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. On the other hand, nonresidents are taxed on income effectively connected with the U.S. Since this is key to the taxation regime, tax advisers working with performers or athletes must be able to differentiate between the two. For Americans, incorporating can generate substantial tax savings; however, there are drawbacks to this classification that need to be understood.

In addition to structuring opportunities, there are special treaty benefits and exclusions available for nonresident performers who reside in treaty jurisdictions and central withholding agreements (CWAs) with the IRS than can aid in reducing the burden of withholding taxes.

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



  1. Overview
  2. U.S. resident athletes and entertainers
  3. Nonresident athletes and entertainers
  4. Structuring opportunities and considerations
  5. Tax treaty relief
  6. Withholding obligations


The panel will explain these and other critical issues:

  • Applying U.S. residency tests
  • Benefits of special treaty exclusions and benefits for performers
  • Utilizing a central withholding agreement with the IRS as a withholding alternative
  • Steps to take to reduce the effective tax rate for performers


Bowley, Jeffrey
Jeffrey J. Bowley, CPA, MT

Joseph W. Bowley & Co.

Mr. Bowley provides technological accounting & financial solutions to entrepreneurs, startups and established...  |  Read More

McCormick, Patrick
Patrick J. McCormick, J.D., LL.M.

Culhane Meadows Haughian & Walsh

Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting...  |  Read More

Access Anytime, Anywhere

CPE credit is not available on downloads.