On Tuesday, March 19, 2013 we posted
Professional Golfer Sergio Garcia "Whiffs" Tax
Case regarding US Tax on "Image Rights" which discusses
that the US Tax Court has ordered professional golfer Sergio Garcia to pay tax
on endorsement income he had claimed was tax-free under the US-Switzerland tax
treaty.
The court decided Garcia's contract with his sponsor TaylorMade had attributed
too much of the money to royalty payments for image rights, which the treaty
exempts from US tax.
Mickelson capped a dominant fortnight in Scotland by shooting a final round 66 to come from behind and win The Open Championship. He also won the Scottish Open the previous week. For his two weeks of play, earned £1,445,000, or about $2,167,500.
The United Kingdom, which has
authority to set Scotland’s tax rate until 2016, graduates to a 40% tax rate
when income hits £32,010 then 45% when it reaches £150,000.
Mickelson will pay £636,069 ($954,000, or 44.02%) on his Scottish earnings.
But that’s not all. The UK will tax
a portion of his endorsement income for the two weeks he was in Scotland. It
will also tax any bonuses he receives for winning these tournaments as well as
a portion of the ranking bonuses he will receive at the end of the year, all at
45%.
The good news for Mickelson is that
he can take a foreign tax credit on his US return so he is not double-taxed at
the federal level on this income. The bad news is that the credit does not
cover self-employment taxes (2.9%) or the new Medicare surtax (0.9%).
Additionally, California does not have a foreign tax credit so he will have to
fork out 13.3% there as well. Although he receives federal deductions for his
California tax and half of his self-employment tax, these deductions do not
benefit him on this income because as they reduce his federal tax they reduce
his foreign tax credit.
Without considering expenses,
Mickelson will pay 61.12% taxes on his winnings, bringing his net take-home
winnings to about $842,700. When expenses are considered (10% to caddy Jim
“Bones” Mackay, airfare, hotel, meals, agent fees on endorsement
income/bonuses—all tax deductible here and in the UK), his take-home will fall
closer to 30%.
at Marini & Associates, P.A.
for a FREE Tax Consultation
or Toll Free at 888-8TaxAid (888 882-9243).
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