Your Advisory
Deal Authorization Memo
Athlete
Stefan Jovanović
Home country
Serbia
Visa
F-1 · no work authorization on file
Prepared for
Athlete, agent, immigration counsel, and cross-border CPA
The deal
Footwear endorsement campaign — $450,000. Originally proposed as a U.S. shoot; restructured to be performed in the athlete's home country over summer break to remove U.S. work-authorization exposure and as foreign-source income.
Determination
SCREENED
No issues identified from the facts entered — not a determination
The limited facts entered did not surface a known issue. This is not a determination that the deal is permitted — an attorney makes that call.
- The activity is performed while the athlete is physically outside the U.S. — generally outside U.S. work-authorization rules and treated as foreign-source income.
- Document where each activity was performed; the work-location record is the diligence trail if status is ever questioned.
Conditions this rests on
- The work must genuinely occur abroad — document travel dates and the location of each activity.
- No U.S.-based services may be bundled in (no U.S. shoot days, appearances, or fulfillment).
Documentation on file
- Work-location log entry for each activity (date, place, deliverable, amount)
- Executed agreement and scope of services
- Travel record evidencing where the work occurred
- W-8BEN and treaty position (for withholding)
- DSO notification / acknowledgment
Required sign-offs
Work-location log — dated evidence the activity occurred abroadSignature / date
Cross-border CPA — confirm foreign-source characterizationSignature / date
Athlete acknowledgment — reviewed and understood before signingSignature / date