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Holo & Talansky: Taxing the Business of Sports

Robert Holo & Jonathan Talansky (both of Simpson Thacher & Bartlett, New York) have published Taxing the Business of Sports, 9 Fla. Tax Rev. 161 (2008).  Here is part of the Introduction:

While sports owners inevitably grapple with ordinary issues of business taxation, the peculiarities of sports involve a unique set of problems that may require particular scrutiny. Part II of this paper will address issues relating to prepaid income and the timing of income recognition associated with common sports transactions, as well as a 2004 Revenue Procedure that may offer greater flexibility and tax planning alternatives to sports franchises. Part III examines the singular role of certain intangible assets in the tax profile of sports teams and chronicles the evolving tax treatment of player contracts. In this area, recent legislative and regulatory action stands to affect significantly the valuation of sports franchises and the structuring of their acquisitions. Part IV takes a bit of a digression and briefly addresses the well publicized topic of the “record home-run ball.”


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