Boulez v. Commissioner
United States Tax Court
83 T.C. No. 31, 83 T.C. 584 (1984)

- Written by Sarah Holley, JD
Facts
Pierre Boulez (plaintiff) was a French citizen and German resident who, under a contract with CBS Records, conducted multiple orchestral recordings in the United States in exchange for a percentage of the retail sales of the recordings. The contract stated that CBS Records would own all of the recordings that Boulez made and referred to Boulez’s remuneration as royalties. The Internal Revenue Service (IRS) found a deficiency in Boulez’s individual income tax return. Boulez argued that the remuneration from CBS Records were royalties and therefore exempt from taxation in the United States under the United States’ tax treaty with Germany. The IRS argued that the remuneration was income from personal services rendered in the United States and therefore not subject to any treaty exemption.
Rule of Law
Issue
Holding and Reasoning (Korner, J.)
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