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Can a resident alien athlete or entertainer enter into a CWA

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Question:

Can a resident alien athlete or entertainer enter into a CWA

Answer:

No, a resident alien athlete or entertainer cannot enter into a CWA (contemporaneous written acknowledgment). The regulations under section 1441 of the Internal Revenue Code, which authorize CWAs, do not apply to resident aliens.

Sources:
Publication 519 (2023)
Rev. Proc. 89-47
Publication 515 (2024)
Rev. Proc. 2017-21

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