Jeffrey Dunlop


At first glance, it does not appear that taxation issues facing the international athlete and developing free trade between North and South America are closely related; they represent very different aspects of cross-border transactions and investment. On the other hand, they may be related when viewed as sequential steps in the process toward developing sustained economic relationships. This article will attempt to bridge that gap. First, Part II of this article discusses the current United States approach toward taxation of international athletes. Next, Part III reviews the history and issues facing tax treaty negotiations between the United States and developing countries, with a focus on the negotiation sticking points between the United States and Brazil. Finally, Part IV of this article argues that a multilateral tax treaty regarding the singular issue of international athletes is a viable tool to help strengthen economic relations in the Americas. Moreover, this initial treaty will open doors to further economic integration resulting in a positive effect on free trade discussions.