This publication brings together two reports prepared by the Committee on Fiscal Affairs. The first, "Thin Capitalisation", examines the implications for taxation of the different reliance by companies on debt and equity financing. The second, "The Taxation of Income Derived from Entertainment,...

This article analyzes the Tax Court case of Garcia v. Commissioner. The article focuses on two key aspects of Garcia: (1) the classification of an athlete's endorsement income as royalty income rather than services income; and (2) the taxability of that royalty income under an "Artistes and...