The US Tax Court held that the compensation paid to a Swiss resident for use of his image rights in the United States is royalty income that is not taxable in the United States under the US-Switzerland treaty (Sergio Garcia v. Commissioner of Internal Revenue, 140 T.C. No. 6, Docket No. 13649-10 (14 March 2013)). The US Tax Court also determined the proper allocation of income received under the e…