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Content Creators & Influencers

Tax & Accounting for Content Creators and Influencers

You built an audience. Now the money is coming in from YouTube AdSense, TikTok Creator Fund, Twitch subs, brand sponsorships, affiliate links, merch sales, and digital products. Sometimes all at once. The IRS sees all of it. And most CPAs have no idea how to categorize half of these income streams. Each platform has different 1099 types, different payout structures, and different reporting thresholds, all of which need to be tracked and reconciled correctly.

CPA Services for Content Creators & Influencers

The creator economy is massive and growing fast. Goldman Sachs estimated the global creator economy at $250 billion as of March 2025, with the U.S. share between $50 billion and $56 billion. Around 67 million people worldwide identify as content creators. But here's the reality check: only about 4% of creators earn $100,000 or more per year, the median sits around $30,000, and a full 46% earn under $1,000 annually. Brand deal rates vary enormously by tier. Nano creators (under 10K followers) might earn $10 to $250 per Instagram post. Micro creators (10K to 100K) range from $150 to $5,000. Mid-tier (100K to 500K) commands $1,600 to $10,000 per post. Macro creators (500K to 1M) pull $5,000 to $25,000, and mega creators (1M+) can command $10,000 to $50,000 or more for a single post. According to NeoReach's 2025 report, 68.8% of creators cite sponsorships as their primary income source. Whether you're at $5,000 or $500,000, the tax rules are the same, and they're complicated.

Each platform issues different tax forms, and knowing exactly what to expect from each one matters. YouTube issues a 1099-MISC from Google under the entity name 'XXVI Holdings Inc.', aggregating AdSense revenue, YouTube Premium distributions, Super Chat donations, and channel membership fees. TikTok Creator Fund and Creativity Program payments produce a 1099-NEC, but watch for dual reporting if TikTok routes payments through PayPal, which could also issue a 1099-K. Twitch presents a bifurcated reporting structure: a 1099-MISC for subscription and ad royalties (with a $10 royalty threshold) and a 1099-NEC for Bits and service-based income. Kick routes creator payouts through Stripe, generating a 1099-K via Stripe's Connect platform. UGC creators and podcasters typically receive 1099-NECs directly from the paying brand or agency, not the platform. Patreon operates as a third-party settlement organization issuing 1099-K. Ko-fi does not issue 1099s directly; payments route through PayPal or Stripe for 1099-K reporting. Amazon Associates, LTK, and ShareASale generate 1099-NEC forms for affiliate commissions.

Double-reporting risk is real and catches creators every year. The same income can appear on a platform 1099-NEC AND a payment processor 1099-K, creating an IRS mismatch unless properly reconciled. Patreon explicitly warns that Form 1099-K reports gross earnings before fees and refunds, meaning you need to book platform fees and chargebacks as contra-revenue to avoid paying tax on money you never kept. Your NAICS code is 711510 ('Independent Artists, Writers, and Performers') and all income over $400 net triggers self-employment tax at 15.3% (12.4% Social Security on the first $184,500 for 2026, plus 2.9% Medicare uncapped, plus 0.9% Medicare surtax above $200,000 single/$250,000 MFJ).

The One Big Beautiful Bill Act (OBBBA) has changed several important 1099 thresholds that directly affect creators. Section 70432 permanently reverted the 1099-K reporting threshold to $20,000 and 200 transactions, killing the American Rescue Plan Act's $600 threshold that had been causing massive over-reporting headaches. Section 70433 raised the 1099-NEC and 1099-MISC reporting threshold to $2,000 for tax years beginning in 2026 and later, with inflation indexing starting in 2027. This means platforms won't issue a 1099-NEC unless they pay you $2,000 or more. But the income is still taxable even without a 1099. You're required to report all income regardless of whether you receive a form. And if you're in New Jersey, the state maintains its own $1,000 1099-K threshold with no transaction minimum, which is significantly stricter than the federal rules. A 2025 Avalara/Censuswide survey found 74% of gig workers could not identify the correct 1099-K threshold, a knowledge gap that creates real compliance risk.

Gifted products are taxable income at fair market value (the retail price) regardless of dollar amount. There is no IRS-codified minimum threshold in a business context, and IRC Section 132(e) de minimis fringe benefits explicitly do not extend to independent contractors. The Supreme Court in Commissioner v. Duberstein (363 U.S. 278, 1960) established that gifts require 'detached and disinterested generosity,' a standard brand-to-creator shipments almost never meet. Brand trips are valued at the retail price the public would pay and reported as barter income. Viewer 'donations' and tips on Twitch Bits, YouTube Super Chats, TikTok Live gifts, PayPal, or any platform are taxable self-employment income, not gifts. If the IRS questions it, analogous rulings regarding celebrity 'swag bags' establish clear precedent: items provided to create brand awareness constitute taxable income. Best practice: formally refuse or return unsolicited, high-value items you don't intend to report as income.

One tax trap that catches a lot of creators off guard: self-created content is NOT a capital asset under IRC Section 1221(a)(3). If you sell a YouTube channel, license your back catalog, or sell digital products you personally created, the proceeds are ordinary income, not capital gains. You won't get the lower long-term capital gains rate. This applies to everything from selling presets and templates to licensing video content to a media company. The income gets taxed at your ordinary rate, which for many successful creators means 32% or 37% federally plus NJ rates up to 10.75%. Brand deals sometimes include equity compensation. If a company offers you stock or equity, IRC Section 83(a) requires you to include the fair market value as income when the stock vests. You have the option to file a Section 83(b) election within 30 days of receiving the stock using Form 15620. Miss that 30-day window and you're locked into Section 83(a) treatment, potentially paying tax on a much higher value at vesting.

The OBBBA introduced the 'No Tax on Tips' federal deduction, valid through December 31, 2028, allowing individuals who customarily receive tips to deduct up to $25,000 per year in qualified tip income from federal taxable income. Digital content creators have been classified as eligible recipients for this deduction. For streamers receiving Twitch Bits, YouTube Super Chats, or TikTok Live gifts, which function mechanically as voluntary digital gratuities, this provision offers a meaningful tax shield on micro-transactions. The deduction phases out for single filers with MAGI exceeding $150,000 ($300,000 MFJ), and tip income remains fully subject to self-employment taxes. This is a new planning tool worth evaluating each year.

If you sell digital products from New Jersey, the sales tax situation gets complicated fast. Under N.J.S.A. 54:32B-2(zz) through (ddd), New Jersey taxes 'specified digital products' at 6.625%. This includes audio-visual works, audio works, and digital books. Presets, Lightroom templates, LUTs, and Photoshop actions don't fit neatly into any of those categories, and there's no definitive guidance from the NJ Division of Taxation. Online courses present another gray area: a downloadable video course is likely taxable as an audio-visual work, while a streaming-only course with no download option is likely exempt as a service. Platform choice matters enormously. Fourthwall operates as a Merchant of Record, handling all sales tax collection and remittance on your behalf. Shopify, Kajabi, and Stan Store do not. On those platforms, you bear full responsibility for registering, collecting, and remitting sales tax in every state where you have economic nexus.

The S-Corp question comes up constantly, and for NJ creators, the math must account for the state's exceptionally high compliance overhead. At $50,000 net profit, S-Corp election actually yields a net financial loss of approximately $2,555 compared to remaining a default LLC. At $75,000 with a $40,000 reasonable salary, you save roughly $5,355 in SE tax, but after $3,500 in compliance costs and the NJ CBT minimum, net savings fall to a marginal $1,855. At $100,000 with a $60,000 salary, net savings are roughly $1,450 after costs. At $150,000 with a $75,000 salary, gross savings approach $9,725, netting approximately $6,225 after overhead. This is the definitive 'clear win' threshold. At $250,000, net savings reach approximately $11,300 annually. Use the S-Corp savings calculator to model the break-even point for your situation. One critical NJ point: forming your LLC in Wyoming, Nevada, or Florida while living in New Jersey saves you exactly $0. NJ taxes residents on worldwide income regardless of where the entity is formed (N.J.S.A. 54A:5-1). I see this mistake constantly, and it usually comes from bad advice on YouTube or TikTok.

For creator S-Corps, the IRS scrutinizes 'reasonable compensation' heavily because a content creator's income is almost entirely driven by their personal brand and labor. The popular '60/40 rule' has no IRS endorsement or legal standing. The IRS and tax courts generally prefer the Cost Approach (the 'Many Hats Approach') for solo operators: break down your total working hours into distinct functional roles (20% video editing, 30% marketing and brand pitching, 40% on-camera talent, 10% administrative bookkeeping), then apply regional wage benchmarking data to each role. BLS data for 'Writers and Authors' ($73,150 median), 'Producers and Directors' ($86,610), and 'Multimedia Artists' ($85,000) provides defensible benchmarks. Set a conservative base salary through regular payroll, then issue a year-end bonus once annual profit is known, documenting the methodology in corporate minutes.

New Jersey's estimated tax rules are stricter than federal and catch a lot of creators by surprise. The NJ underpayment trigger is just $400, compared to $1,000 at the federal level. The NJ safe harbor requires paying 80% of current-year tax, compared to 90% federally. And the NJ penalty rate runs approximately 10% compounded quarterly, making missed state payments exceptionally costly for creators experiencing sudden viral growth. For creators with Q4-heavy income (most of you, thanks to holiday brand deals and year-end ad revenue spikes), the annualized income installment method on Form 2210, Schedule AI is critical. This method lets you calculate each quarter's estimated payment based on actual income received through that period, rather than dividing projected annual tax into four equal payments. If 60% of your income arrives in Q4, the annualized method can dramatically reduce or eliminate underpayment penalties.

New Jersey decouples from several key federal tax benefits, creating a 'decoupling trap' that catches creators who assume NJ mirrors federal treatment. NJ completely disallows federal bonus depreciation. Any amount claimed as bonus depreciation on the federal return must be added back to NJ state income and depreciated using the Alternative Depreciation System (ADS) with straight-line depreciation. A $100,000 studio buildout fully expensed federally yields only approximately $14,285 per year in NJ for 7-year ADS property. NJ caps Section 179 at $25,000 (compared to the federal $2,560,000 for 2026). NJ does not recognize the Section 199A QBI deduction, so a creator netting $150,000 pays NJ GIT on the full $150,000 with no 20% reduction. NJ does not allow HSA deductions. NJ does not allow SEP-IRA deductions, but does allow 401(k) deferrals and employer profit-sharing contributions. And one favorable divergence: NJ allows 100% deduction for business meals versus the federal 50% limitation.

Hiring help for your content business introduces NJ-specific risk. New Jersey's ABC test under N.J.S.A. 43:21-19(i)(6) is one of the strictest worker classification tests in the country. Prong B requires that the worker performs services 'outside the usual course of business' of the employer. That means hiring a video editor, graphic designer, or virtual assistant as a 1099 contractor is risky if they're performing functions that are regular and integral to your content business. NJ has collected $84 million in wage assessments since 2018 from businesses that misclassified workers. If you need ongoing help, talk to me about whether you should be running payroll instead of issuing 1099s.

If you have kids, there's a legitimate tax strategy worth exploring. Children under 18 employed by a parent's sole proprietorship are exempt from FICA under IRC Section 3121(b)(3)(A) and from FUTA under Section 3306(c)(5). Your child can earn up to the standard deduction amount ($15,000 in 2026, indexed for inflation) completely tax-free, and the wages are deductible to your business. They can do legitimate work like managing social media, organizing files, appearing in content, or handling inventory for merch. This only works for sole proprietorships and spousal partnerships. S-Corps and C-Corps do NOT qualify for the FICA exemption. State-level Coogan Laws for child influencers are expanding rapidly. Following California's AB 1880 and SB 764, states like Illinois and Minnesota now require depositing 15% to 65% of gross earnings into a trust account when a minor's likeness appears in 30% or more of compensated content. NJ hasn't passed a specific digital Coogan law yet, but the legislative momentum suggests it's coming.

Every platform has its own tax quirks. I've written detailed guides for each one: YouTube Taxes covers AdSense mechanics, the 55/45 split, and hobby vs. business rules. Twitch Streamer Taxes breaks down subs, bits, donations, and the Kick 95/5 comparison. TikTok Taxes covers all nine monetization programs, including TikTok Shop and LIVE gifts. OnlyFans Taxes addresses the 80/20 payout, LLC privacy structures, and deduction gray areas. And UGC Creator Taxes covers gifted product valuation, brand deal structures, and when to formalize your side hustle into a business.

This guide covers the core tax rules for YouTubers, TikTokers, Twitch streamers, Kick streamers, Instagram influencers, UGC creators, Substack writers, podcasters, and digital product creators across every niche. The platform-specific subpages linked above go deeper into each one.

Common Tax & Accounting Challenges for Content Creators & Influencers

Brand deals, ad revenue, gifted products, affiliate income, multi-platform payouts. Your tax situation is more complex than most CPAs realize. Work with one who actually understands how creators earn.

  • Multi-platform income from 6+ sources with different 1099 types (1099-NEC, 1099-MISC, 1099-K) and different thresholds, requiring a platform-by-platform revenue map to avoid IRS mismatches
  • Double-reporting risk: same income appearing on both platform 1099-NEC and payment processor 1099-K; Patreon 1099-K reports gross before fees, chargebacks, and refunds
  • OBBBA threshold changes: 1099-K reverted to $20,000/200 transactions (Section 70432), 1099-NEC raised to $2,000 for 2026+ (Section 70433), but income remains taxable below thresholds
  • NJ 1099-K threshold: $1,000 with no transaction minimum (stricter than federal $20,000/200 transactions), meaning NJ may issue forms when federal does not
  • Gifted products taxable at FMV at receipt: no minimum threshold in business context; IRC Section 132(e) de minimis exclusion does not apply to independent contractors (Duberstein, 363 U.S. 278)
  • Viewer tips and donations treated as taxable SE income, not excludable gifts; No Tax on Tips deduction (up to $25,000, 2025-2028) phases out at $150K MAGI single/$300K MFJ
  • Self-created content not a capital asset under IRC Section 1221(a)(3): channel sales, licensed content, and digital product proceeds generate ordinary income, not capital gains
  • Brand deal equity compensation: IRC Section 83(a) income at FMV on vesting, Section 83(b) election required within 30 days on Form 15620; IRC Section 409A penalties of 20% plus interest for noncompliant deferred compensation
  • NJ sales tax on digital products: 6.625% on specified digital products, but presets, templates, LUTs, and courses fall in gray areas with no definitive NJ Division of Taxation guidance
  • Platform compliance implications: Fourthwall (Merchant of Record) handles sales tax vs. Shopify/Kajabi/Stan Store (creator bears full responsibility for multi-state nexus registration)
  • Quarterly estimated tax underpayment risk: NJ $400 trigger, 80% safe harbor, ~10% penalty rate compounded quarterly, all stricter than federal
  • Q4-heavy creators need annualized income installment method (Form 2210, Schedule AI) to avoid unnecessary penalties on uneven income
  • Worker classification risk when hiring editors and VAs under NJ ABC test Prong B: $84M in NJ wage assessments since 2018; penalties up to $1,000/worker for subsequent violations
  • NJ depreciation decoupling trap: bonus depreciation fully disallowed, Section 179 capped at $25,000 vs. federal $2,560,000, requiring separate federal and NJ depreciation schedules
  • NJ does not recognize Section 199A QBI deduction: a creator netting $150K pays NJ GIT on the full $150K with no 20% reduction
  • NJ does not recognize HSAs: contributions not deductible, growth taxable at the NJ level
  • NJ does not allow SEP-IRA deductions but does allow Solo 401(k) deferrals and employer profit-sharing contributions, making retirement vehicle choice critical for NJ state tax savings
  • Forming LLC in WY/NV/FL while living in NJ saves $0: NJ taxes residents on worldwide income (N.J.S.A. 54A:5-1)

What Monaco CPA Provides

Tax preparation, planning, and compliance services tailored to your industry.

Creator Tax Returns (1040, 1120-S, Schedule C)

Individual and business tax returns reconciling all platform income: YouTube, TikTok, Twitch, Kick, Instagram, Patreon, Substack, affiliate networks.

Entity Selection & S-Corp Planning

S-Corp election analysis based on your income level, accounting for NJ's high compliance overhead.

Quarterly Estimated Tax Planning

Quarterly estimated payment calculations using the annualized income installment method (Form 2210, Schedule AI) for creators with Q4-heavy income.

Gifted Product & Brand Deal Tax Handling

Proper FMV determination for gifted products, comped travel, brand trips, and barter arrangements.

Digital Product Sales Tax & Multi-State Nexus

NJ digital product sales tax analysis (6.625% on audio-visual works, audio, digital books). Platform strategy: Merchant of Record platforms (Fourthwall) vs.

Retirement & Benefits Planning

Solo 401(k) setup for creator businesses: 2026 employee deferral up to $24,500 (under 50), $32,500 (ages 50-59 or 64+), $35,750 (ages 60-63 per SECURE 2.0).

Child Employment & Family Tax Strategy

Structuring child employment in your sole proprietorship for FICA exemption under IRC Section 3121(b)(3)(A).

Overseas Contractor & Multi-State Compliance

W-8BEN collection, withholding analysis under IRC Section 1441, treaty-based rate reductions.

Free Tool

See If S-Corp Election Makes Sense for Your Content Creators & Influencers Business

Most content creators & influencers owners make the switch somewhere between $60K and $80K in net income. Use the free calculator to compare sole prop SE taxes vs. S-Corp payroll taxes, including NJ compliance costs.

Calculate Your S-Corp Savings

Frequently Asked Questions

Are gifts from viewers (donations, Twitch Bits, PayPal tips) taxable?

Yes, all of them. Viewer payments are self-employment income, not excludable gifts. The Supreme Court in Commissioner v. Duberstein (363 U.S. 278, 1960) established that gifts require 'detached and disinterested generosity.' Your audience pays you because they receive entertainment content, not out of pure generosity. Twitch Bits, SuperChats, TikTok Live gifts, PayPal 'donations,' Ko-fi tips, and all similar payments are ordinary SE income subject to both income tax and self-employment tax (15.3% on the first $184,500 in 2026). The OBBBA's No Tax on Tips deduction may allow you to deduct up to $25,000 in qualified tip income through 2028, but it phases out at $150,000 MAGI for single filers and the tip income remains subject to SE tax.

How are gifted products from brands taxed?

Products received for promotion or content creation are taxable income at fair market value (generally the retail price) in the year received. There is no IRS-codified minimum threshold for business context. The '$100 threshold' floated online is practitioner convention, not law. IRC Section 132(e) de minimis fringe benefit exclusions explicitly do not apply to independent contractors. The IRS has ruled that celebrity 'swag bags' at awards shows constitute taxable income when items are provided to create brand awareness. Unsolicited PR shipments you never promote are the most ambiguous case, but returning unwanted products before use eliminates the tax liability. Comped hotel stays and travel for brand trips are taxable at FMV, with offsetting business expense deductions available if the trip was genuinely for business.

Which platform income gets which 1099 form?

YouTube AdSense: 1099-MISC from 'XXVI Holdings Inc.' aggregating ad revenue, Premium, Super Chats, and memberships. Twitch: 1099-MISC for subscription and ad royalties ($10 threshold), plus 1099-NEC for Bits. TikTok Creator Fund: 1099-NEC. Kick: 1099-K via Stripe. Instagram/UGC brand deals: 1099-NEC from the paying brand or agency. Patreon: 1099-K ($20,000/200 transactions federally, $1,000 in NJ). Ko-fi: 1099-K via PayPal or Stripe. Amazon Associates: 1099-NEC. The 2026 1099-NEC/MISC threshold rises to $2,000 (OBBBA Section 70433) with inflation indexing starting 2027. The 1099-K threshold is permanently $20,000 and 200 transactions (Section 70432). NJ maintains a stricter $1,000 state threshold with no transaction minimum.

Should I form an LLC or S-Corp for my creator business?

An LLC is a legal structure. It does not by itself change your tax treatment. A single-member LLC is a disregarded entity under Treas. Reg. Section 301.7701-3; you still pay SE tax on 100% of net income. The S-Corp election (Form 2553) is what creates the tax savings. In NJ, the S-Corp doesn't produce meaningful net savings until approximately $150,000 in consistent net income due to NJ's high compliance overhead (payroll processing, Form 1120-S and CBT-100S preparation, NJ CBT minimum tax of $375 to $1,500, employer state payroll taxes). At $150K, net savings are approximately $6,225. At $250K, approximately $11,300. Forming your LLC in Wyoming or Nevada while living in NJ saves nothing. NJ taxes residents on all worldwide income.

Are my camera, laptop, and home office deductible?

Camera, lighting, microphones, computers, and other equipment used exclusively for content creation are deductible. Section 179 allows immediate expensing up to $2,560,000 in 2026; 100% bonus depreciation is now permanent under OBBBA for property acquired after January 19, 2025. Software subscriptions (Adobe Creative Cloud, ChatGPT Plus, Descript, music licensing) are current-year expenses under IRC Section 162. AI tool subscriptions (Midjourney, Runway, DALL-E) are fully deductible as ordinary business expenses per Treasury T.D. 10022, which classified cloud transactions as services. Home office: you must have a designated space used exclusively and regularly for business. NJ does not allow bonus depreciation and caps Section 179 at $25,000, so your NJ deduction will be significantly smaller than federal in the year of purchase. You need two separate depreciation schedules.

How do I handle quarterly estimated taxes when my income is unpredictable?

The annualized income installment method (Form 2210, Schedule AI) is the right approach if income is Q4-heavy. Instead of paying equal installments based on projected annual income, you compute each quarter's payment based on actual year-to-date income, which can dramatically reduce underpayment penalties. Federal safe harbor options: pay 90% of current-year tax OR 100% of prior-year tax (110% if prior-year AGI exceeded $150,000). NJ is stricter: 80% current-year safe harbor, $400 underpayment trigger (vs. federal $1,000), and approximately 10% penalty rate compounded quarterly. Missing NJ estimated payments is one of the most common and costly mistakes I see from creators.

What OBBBA changes affect content creators in 2025-2026?

Several OBBBA provisions directly impact creators. Section 70432 permanently reverted the 1099-K threshold to $20,000 and 200 transactions. Section 70433 raised 1099-NEC/MISC threshold to $2,000 for 2026+ with inflation indexing starting 2027. 100% bonus depreciation is now permanent for property acquired after January 19, 2025 (IRS Notice 2026-11). The QBI deduction under Section 199A is now permanent with a minimum $1,000 QBI requirement for 2026+. The SALT deduction cap increased to $40,000 (from $10,000). The No Tax on Tips provision allows deducting up to $25,000 in qualified tips (2025-2028), phasing out at $150K MAGI. NJ still does not conform to federal bonus depreciation, caps Section 179 at $25,000, and does not recognize the QBI deduction.

Can I hire my teenager to help with my content business?

Yes, and it can be a great tax strategy if structured properly. Children under 18 employed by a parent's sole proprietorship are exempt from FICA taxes under IRC Section 3121(b)(3)(A) and from FUTA under Section 3306(c)(5). Your child can earn up to the standard deduction amount ($15,000 in 2026, adjusted annually) completely tax-free. The wages are deductible to your business. Children can do legitimate work: managing social media, organizing files, appearing in content, merch fulfillment, or basic admin. Keep time records and pay reasonable rates. This strategy ONLY works for sole proprietorships and spousal partnerships. S-Corps do not qualify for the FICA exemption. Watch for Coogan Law developments: states are rapidly expanding trust account requirements for child influencers.

Why is the Solo 401(k) better than a SEP-IRA for NJ creators?

Because of NJ's retirement plan non-conformity trap. NJ does not allow deductions for SEP-IRA contributions under its Gross Income Tax. A creator contributing $50,000 to a SEP-IRA gets the full federal deduction but pays NJ income tax on that entire $50,000. At NJ's 6.37% rate ($75,001 to $500,000 bracket), that's an additional $3,185 in NJ state taxes compared to making the same contribution through a Solo 401(k). Under N.J.S.A. 54A:6-21, NJ explicitly allows deductions for both employee deferrals and employer profit-sharing contributions to qualified 401(k) plans. The Solo 401(k) also lets you hit the $72,000 combined maximum at a lower income level through its dual employee deferral plus employer contribution structure.

What happens if I move out of NJ to a tax-free state?

NJ enforces aggressive residency audits based on domicile and statutory residency. To successfully change domicile, you must prove permanent severing of ties: voter registration, driver's license, vehicle registration, bank accounts, and business activities all need to move. NJ auditors use cell phone GPS data, credit card statements, E-ZPass records, and social media to verify physical presence. Even if you establish domicile elsewhere, you can still be taxed as a NJ Statutory Resident if you maintain a 'permanent place of abode' in NJ and spend more than 183 days in the state. Any part of a day counts. Retaining a NJ home while traveling full-time leaves your domicile intact. NJ's reciprocal convenience rule (P.L. 2023, c.125) also complicates things for creators working with NY-based agencies.

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IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, I inform you that any U.S. federal tax advice contained herein is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.

IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, I inform you that any U.S. federal tax advice contained herein is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.

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