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Live sports broadcasting rights exclude live-feed payments from royalty, while non-live rights remain taxable and require withholding.

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Full Text of the Document

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....Live sports broadcasting rights do not transfer copyright in a live telecast capable of generating royalty income; therefore, consideration attributable to the live feed is not royalty. Repeat or other non-live telecast rights remain within royalty treatment. Composite media-rights consideration is apportioned using established viewership data: 93% for live broadcasting and 7% for non-live broadcasting. Tax-disallowance for failure to deduct tax applies only to the payment allocated to non-live rights, requiring consequential recomputation of the disallowance.....

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