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November 17, 2016 In the Stacks

Taxation of Entertainers, Athletes, and Artists

By Luisa Andonie, University of Miami School of Law, Coral Gables, FL

Taxation of Entertainers, Athletes, and Artists by Lionel S. Sobel, American Bar Association (2015), ISBN-13: 9781627229807, Paperback $99.95.

Attorneys and students alike will rejoice to discover there is such a thing as a tax book that is agreeable to read. While tax practitioners may find Taxation of Entertainers, Athletes, and Artists overly basic, the rest of us will appreciate its depth and clarity.  It boasts the accessibility of a study aid and the straightforwardness of a practice manual.

Lionel S. Sobel, the author, teaches a class on taxation of entertainers at UCLA and was chairman of the ABA Forum on the Entertainment and Sports Industries.  He manages to break down complexities into comprehensible dialogue, separating topics neatly into 14 chapters for ease of reference. He says he “strived to make this book as easy to read as a book about tax can be.”

Simple does not mean simplistic. The first part of the book explores domestic treatment, while the second plunges into the complexities of international taxation. It addresses the taxation of income earned in the U.S. by nonresident alien entertainers, as well as other countries’ treatment of domestic income earned by U.S. citizen and U.S.  resident-alien entertainers. The book then explores possible relief the U.S. makes available for both citizens and resident aliens in the U.S. when they pay tax in other countries.

Throughout this in-depth exploration, Sobel writes in a humorous tone, quoting Mark Twain and translating the tax court’s stance into colloquial language. His avoidance of legalese makes tax jargon accessible to readers of varied academic and professional backgrounds. Throughout the detailed analysis, he offers insightful commentary—such as “it’s surprising how little published law there is on this issue”—as though he were a friendly tour guide.

Employing contractions and well-placed humor, his informal writing style lends the book a dinner conversation tone. Nonetheless, he maintains scholarly accuracy with citations to IRS revenue rulings and similar sources. Of particular value, he translates the IRS’s examples into illustrations that omit the complexities, where appropriate, to provide explanation.

Unlike textbooks, which often focus on theories, Sobel presents issues with a pragmatic, answer-seeking approach. By laying out issues in the practical client context in which they may arise, he provides aspiring and established entertainment lawyers a closer understanding of fundamental tax statutes. Similarly, he defines terminology with simple examples, providing non-tax lawyers the ability to recognize tax issues and be able to refer clients to a tax specialist.

The book covers the essential principles and cases taught in an introductory income tax course, making it a study tool for students currently taking even non-entertainment tax courses. Like a study outline, it synthesizes factors into readable bullet points. After each concept, there are examples making it comparable to the Examples and Explanations series. At the beginning of each chapter, there is an outline of the sub-headings within the chapter.

Unlike a black letter law study aid, the book provides precise footnotes to the Internal Revenue Code, Treasury Regulations, and cases, as well as IRS guidelines and news releases, making it a good starting point for further research.

Even the physical design of the book prioritizes the reader, with a large font size, clean formatting, and paperback portability. At fewer than 400 pages and smaller than a textbook, it is not a dust-gathering tome. Indeed, interspersed with flow charts, tables, and tax form images, the book is a reliable reference just as much as an engaging guidebook.

The book is available for purchase on the ABA Website.