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 endorsement contract between the image rights and the personal services that were required to be performed. The petitioner in the present case was a world-renowned professional golfer, who was a Spanish...