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- Title
Out of Bounds: How Garcia v. Commissioner Illustrates the Impossibility of Applying the Rules of Taxation Affecting Nonresident Alien Athletes.
- Authors
Tymkovich[86, Jay L.
- Abstract
The article discusses impossibility of applying the rules of taxation affecting nonresident noncitizen athletes in the light of Garcia v. Commissioner court case. Topics includes no royalty income paid by golfer Sergio Garcia because of taxpayer friendly tax rates of Switzerland; difference between royalties and personal services made by tax court; and tax imposed on U.S. citizens and resident noncitizens subject to the U.S. federal income tax.
- Subjects
UNITED States; TAXATION of athletes; INCOME tax; GARCIA, Sergio, 1980-; ROYALTIES (Copyright); TAX courts; ACTIONS &; defenses (Law); TAX laws
- Publication
Tax Lawyer, 2017, Vol 70, Issue 3, p805
- ISSN
0040-005X
- Publication type
Article