프로골프선수의 후원소득에 대한 과세 - 미국조세법원 판결(136 T.C. No. 27)을 중심으로 -

Recently, as sports industry grows rapidly over the world, more and more domestic players are marching into foreign countries for seeking more opportunities. In addition, overseas foreign players also march into Korea. The case which this article is going to research is the case that Retief Goosen who is a golf player and resides in England received endorsement income while make various companies to use his right of name or right of likeness when playing at USA and it became an issue how is the characteristic of such endorsement income and if the endorsement income is included to royalty income, whether such royalty income is attributed to U.S. Though this case is suggested in U.S. and the tax treaty between U.S. and UK became an issue, it is a proper case to research the issue of tax law which can be occurred when a sports player receives a endorsement income while making sports activities at foreign countries. This article first reviewed the judgment of tax court and the overview of this case, researched how tax law in Korea impose a tax for the income which foreign sports player receives, and then considered problems and improvements of tax law in Korea focusing on issues related to this case.