Category: Legal Resources

IRS

Taxation of cryptocurrency forks and airdrops

In Revenue Ruling 2019-24 the IRS considered what are the tax consequences of crptocurrency forks and airdrops.  Those of us who hold, or held, cryptocurrency during widely-followed forks, such as Bitcoin’s 2018 fork into Bitcoin and Bitcoin Cash, know the drill.  The development community can’t agree on fundamental issues about the particular cryptocurrency, such as the amount of data each “block” should carry and how often such blocks should be validated on the blockchain.  Rather than compromising, one faction or the other generates a new code base using the existing coin and adds (or subtracts) their modifications, later releasing the new code into the world as a new coin or token.  Voila, the “fork” (as in a fork in the road) has birthed a new cryptocurrency on its very own blockchain, to thrive or survive alongside its “parent” coin.  Sometimes (as has been the case with Bitcoin Cash), that new coin thrives quite handsomely, resulting in increased wealth in the hands of the HODLer.  Money for nothing?  According to the IRS, actually, no.

The Revenue Ruling’s definitions of cryptocurrency and the mechanics of forking and airdrops is, to the credit of the IRS, spot on.  Someone has been doing their homework into what exactly they are looking at, which is important, since bad inputs make for bad outputs.  In summary, the Ruling notes that the end result of the fork is one of two scenarios:  (i) the taxpayer receives the new cryptocurrency, which is credited to his account or otherwise received by him (via “airdrop”, in the terms of the opinion); or (ii) the taxpayer does not receive the new crypto for any number of reasons, the one cited being where the exchange on which the taxpayer had her pre-fork crypto does not support the new coin, and that crypto-holder’s rights vanish into thin air.

The first conclusion the IRS comes to, which is that there is gross income to the taxpayer where he or she receives the forked coin is, in my view, correct.  Under classic income tax laws there is a clear “accession to wealth”, that is, you have more money in your pocket (perhaps a lot more) post-fork than pre-fork.

Not all income, however, is created equal in the eyes of the tax law.  Once you determine you have income you must then consider the character of that income, that is, capital, ordinary, or something else.  There are books written about these distinctions.  For our purposes, “ordinary” income includes things like a salary or proceeds from the sale of your business’ inventory.  Capital gain (or loss for that matter), in contrast, relates to purchases and sales of “capital assets”.  Capital assets are, for most people, their investments, perhaps including real estate, stocks and bonds, and cryptocurrency.  This distinction is critical, since different types of income are subject to different income tax rates.

The timing matters too – ordinary income is recognized the minute you either receive it (for cash basis taxpayers) or when “all events” have occurred (for accrual basis taxpayers) that result in the taxpayer having dominion and control over the assets.  For capital assets there is a taxable event where the property is “sold or exchanged”, that is, in some cases, mere receipt of a capital asset will not always trigger tax consequences.  Rather, the law keeps a kind of “tally” of the amount of tax you will have to pay (at some point) in what’s called the “basis” of the asset.  The “basis”, in plain language, is the amount of your investment in an asset.  If the price at sale is above your basis, voila, capital gain.  If the price is below it, capital loss.

Let’s take stock splits as an example.  Let’s say you bought 1 share of Apple (AAPL) at $300.00 (everyone seems to like using Apple as an example). Assume for purposes of this example that you are not a dealer in securities or a professional trader.  What do we know about AAPL in your hands?  (1) That is is (in all likelihood) a “capital asset” (an investment outside of your ordinary trade or business); and (2) Your “cost basis” is $300.00.  As of this evening AAPL is trading at around $317.00.  What do we know now?  We know that, given your basis of $300.00, you now have $17.00 of profit.  If you sold AAPL at $317.00, you would have $17.00 of capital gain.

Fine.  Now assume that AAPL splits two for one, that is, all shareholders of AAPL will receive double the number of their shares, so now you have two shares of AAPL.  Here’s the trick:  your basis in each of the shares is also cut in half.  Therefore, you now have two shares of AAPL.  What’s the price of each?  $158.50.  What’s your basis in each?  $150.00.  What if you sold your two post-split shares of AAPL?  What would your gain be?  Still…$17.00.  See?  Your basis “account” adjusted to reflect the economic reality of the transaction, and spread your initial $300.00 investment across the two shares.

Now imagine that instead of splitting, AAPL pays you a cash dividend of $1.00 per share every quarter (it’s actually around $0.77, but let’s use round numbers).  Dividends are, unlike shares received in a stock split, ordinary income (unless “qualified”, which we won’t get into here).  OK, so why don’t we just treat the dividend like a capital asset, and adjust the basis without having a taxable event?  Well, because the law says so, and perhaps in part because dividends are paid in cash.

The question then is, did the IRS get the second part right, that is, the character of the income that you receive when you receive airdropped tokens from a hard fork.  In my opinion, no.

Forked tokens can feel like “manna from heaven” as the saying goes, but in my opinion they much more closely resemble stock splits than dividends.  My opinion is based on what the IRS has told us for many years – that cryptocurrency is property, not money.  Property held as a capital asset that produces more property (like a stock split) should be treated in the same manner as a stock split, and not as if the forked coins are the same as cash, which they most certainly are not.

For starters, the recipient of the forked coin has extreme price risk from the get-go.  It is not uncommon for a forked coin to spike wildly upon receipt (which, according to the opinion, is then its taxable value) only to collapse violently thereafter.  The token holder may not stand a chance – if you’re not in front of your computer ready, willing and able to sell at the precise moment the coin is received – you may end up with a big tax bill AND an asset that has declined significantly in value.  This is neither consistent nor fair.  A true dividend does not have this inherent risk.  True, currencies are always fluctuating in value against other currencies (and gold), but in the short term, your $1.00 AAPL cash dividend is going to buy the same amount of coffee (perhaps half a cup) whether you’re at your computer when its paid or not.

Second, the IRS has further confounded and complicated cryptocurrency accounting for everyone.  It is bad enough that technically, you have to report either gain or loss for the use (that is, “sale or exchange”, remember?) of crypto for anything, including our proverbial cup of coffee.  Now, you must track the basis of assets with different characters.  This will be a huge challenge for developers of crypto accounting and recordkeeping software, thereby making the neat and clean records the IRS wants taxpayers to keep all the more elusive, and often inaccurate.

In essence, the IRS is looking to have it all ways – cryptocurrency is property subject to the reporting and accounting for capital gain and loss, except when it’s not.  And by the way, if you DO decide to hang on to your airdropped coins, only to sell them later if the price goes way up, you may also have capital gain to pay later, on the very same asset that gave rise to ordinary income upon receipt, even though that asset was really capital in nature all along.

So, brush off your spreadsheets.  Between cold storage wallets, intra-exchange transfers, and now, airdropped, forked coins, it will continue to be a challenge to stay in compliance in the crypto world.

(c) 2020 Good Attorneys At Law, PA

Actor Stephen Baldwin Forks Over Another $100K In Back Taxes to New York

Stephen Baldwin Paid Another $100,000 To New York; Tab Still At $243,068

Actor Stephen Baldwin, of “Celebrity Apprentice” and the “The Usual Suspects” fame, exited a courthouse last week another $100,000 lighter in the wallet.

Back Taxes
If only it was $200 in back taxes

The 47 year-old actor’s tax troubles began with an criminal investigation by New York’s Tax Department and District Attorney, Thomas P. Zugibe. Their inquiry uncovered his failure to file state income tax returns from 2008 to 2010. Back taxes due to the state of New York at the time were over $300,000, including penalties and interest. Police arrested Baldwin in December of 2012 and prosecutors charged him with the felony of “Repeated Failure to File Personal Income Tax Returns.”

Baldwin ended up pleading guilty to the felony charge in March of 2013. He also agreed to pay $400,000 in restitution within one year as part of a plea deal. The arrangement gives him a conditional discharge and no jail, but only if he keeps his end of the bargain. Baldwin, including a prior $100,000 payment, has now paid the State $200,000. District Attorney Zugibe, however, intends on asking Judge Apotheker to jail Baldwin if he can’t meet his March 2014 deadline to pay the entire $400,000 in restitution.

Due to the magic of interest and penalties, New York State Tax Commissioner Thomas H. Mattox also announced that Baldwin still owes $243,068 in back taxes.

Bad Tax Advice

Baldwin claims that his dirty deed was the result of “some really bad suggestions and advice” from lawyers and accountants, according to the New York Post. Commissioner Mattox publicly responded to Baldwin’s dilemma by noting that his Tax Department can arrange installment payment agreements to help people voluntarily resolve back taxes and avoid criminal prosecution.

We work diligently with taxpayers to address issues before they escalate [into criminal charges]. If you have a tax debt, don’t hesitate—take action and contact us to resolve your sitaution.”

Solutions for Back Taxes

Florida residents don’t have to worry about being in Baldwin’s shoes. Florida doesn’t collect state income tax (there are other state taxes, though). Commissioner Mattox’s advice, however, still rings true when it comes to federal income taxes. Short on manpower, the IRS has promoted tax resolution options for unpaid, federal tax debt. The IRS recently made these options more appealing to entice delinquent taxpayers.

Owing back taxes won’t often lead to criminal prosecution. As the Baldwin case illustrates, though, penalties and interest will continue to grow a taxpayers debt until it’s paid off. Ignoring tax debt only makes the problem worse.

Ari Good, JD LLM, a tax, aviation and entertainment lawyer, is the Shareholder of Good Attorneys At Law, P.A. He graduated from the DePaul University College of Law in 1997 and received his LL.M. in Taxation from the University of Florida.

Contact us toll free at (877) 771-1131 or by email to info@goodattorneysatlaw.com.

The Six Rights of Copyright – Part IV: The Right to Publicly Perform

The Right to Publicly Perform is the fourth part in our series on what makes a Copyright.  The prior three rights reviewed are linked below for you to get up to speed.  To refresh, the six parts of copyright are:

  • The right to reproduce the copyrighted work
  • The right to prepare derivative works based upon the work
  • The right to distribute copies of the work to the public
  • The right to publicly perform the copyrighted work
  • The right to publicly display the copyrighted work
  • (sound recording only) The right to digitally transmit to publicly perform the copyrighted work

To try to get behind the curtain of copyright, we’re individually exploring each of these six rights.  An understanding of each and how they operate will allow you, the creator, to be in a better position to take advantage of your copyright.

There are a couple words of caution.  First, the practical effect of these exclusive rights will depend on the type of copyrighted work (literary works, musical works, motion pictures, sound recordings, etc.).  Second, these are exclusive rights.  The law allows only the copyright holder to exercise these rights.

IV.  The Right to Publicly Perform the Copyrighted Work

 

The right to publicly perform means only the copyright owners, or others they authorize, may perform their works publicly. 

 

This right prohibits would be thieves from performing a copyrighted work before the masses and profiting from that theft.  As an exclusive right, anyone wishing to perform a copyrighted work publicly must first obtain permission from the copyright owners.   Copyright owners, at least in the music industry, are often different from the people who created the work in the first place.  How far this right extends depends on answering two questions.

  1. What acts does a performance cover?
  2. When is that performance public?

The definition of performance under the Copyright Act goes beyond the usual examples of live works.  

 

Right to Publicly Perform
Live Public Performance

The term performance certainly covers situations when a person executes a copyrighted work live.  Examples of this include a band playing music in front of a crowd, a theater company performing a ballet before an audience, or people watching a film at the movie theater.  However, it also covers analog or digital transmission of performances by radio, television, and internet streaming.  Examples of transmitted performances include a song played on the radio, a recording of the ballet played on television, and a film screened for locals at a community park.  A performance occurs when the work is done live and when someone transmits a recording of the work.

The definition of public under the Copyright Act means any group beyond family and close friends.

 

A performance is public when the work is performed: (1) in a place open to the public, or (2) at a place where a substantial number of persons outside of a normal circle of a family and its social acquaintances are gathered.  In plain English, music you play for your family (3rd cousins need not apply) or close friends (not everyone on your Facebook friends list) will be a private performance.  Putting out flyers for your upcoming rendition of Britney Spears’ greatest hits, however, would be a public performance.  A performance is also public when you transmit the copyrighted work to a general audience.  This happens when a radio station plays a song, a television show includes that song during a dramatic break up scene, or you stream the song from your internet radio station.  Transmission of a performance will be public unless you restrict it to only your family or close friends.  As a general rule, live or recorded performances that can reach more than a few people will be public performances.

The traditional right to public performance applies to musical works, but not sound recordings.

 

Copyright owners of musical works (songwriters and music publishers) gain the traditional right to public performance.  Copyright owners of sound recordings (record labels), however, are left out in the cold.  A musical work is the composition, arrangement, lyrics, and other details that embody a song.  A sound recording is a specific performance of that musical work.  A musical work results when a band gets together to create an album.  A sound recording results when that same band goes into the studio to record the album.  The practical effect of this distinction is that analog radio stations must obtain a license only for musical works before playing songs on the air.  They don’t need permission from the owners of sound recordings that they actually broadcast.  This is true even though radio stations would have nothing to play without these sound recordings.

Three U.S. Performance Rights Organizations (PRO’s) (BMI, ASCAP, and SESAC) handle the vast majority of licensing and royalty issues for musical works.  There is a vast sea of musical works out there.  PRO’s strive to organize this complex network by licensing musical works on behalf of songwriters and bands.  The PRO’s then collect royalties for the licenses and send checks to the songwriters and bands.  The PRO’s are certainly not charitable entities, however, and take a cut of the royalties to cover the expenses in managing the system.  Some would say too big of a cut.

This oddity of the traditional public performance right has its roots in the history of Copyright.  Copyright protection existed long before people could record music and sheet music (an example of musical works) was the standard.  Copyright protection for musical works was necessary at that time, but obviously not so for non-existent sound recordings.  Copyright law failed to keep up with evolving technology, however, when sound recordings emerged to provide people with a different way to access music.

Congress tried to fix the problem by passing the Digital Performance in Sound Recordings Act (DPSRA).  This created the sixth right of Copyright: the right to perform publicly by digital transmission.  The DPSRA did provide relief for sound recording owners, but also created a volatile two-class system.  Internet radio stations like Pandora and Spotify now have to obtain licenses and pay royalties to copyright owners of musical and sound recordings.  Analog radio stations, on the other hand, continue to enjoy preferential treatment and only have to answer to copyright owners of musical works.  Analog radio stations have a huge financial advantage over internet radio stations as a result.

The right to public performance does have its limitations.

 

For every rule, there are exceptions.  The right to public performance is no different.  Charitable, non-profit, and educational groups may publicly perform copyrighted works without permission if it’s for a reason recognized by law.  Certain businesses may also play copyrighted music without permission for their customers if they play by the rules.

  • The business must receive the music from a licensed radio, cable, satellite, or television broadcast;
  • The business must be on the smaller side;
  • The business must play it only in their establishment;
  • The business cannot charge an admission fee.

A club that charges admission to listen to a recording of the latest, greatest pop album is not going to fall into this exception.  The ubiquitous Fair Use exception to copyright protection can come into play for the public performance right, too.

That’s a lot to go over!  Go ahead and ask questions if you have them, or leave a comment if have an interesting anecdote about the public performance right.

–          Ari Good, Esq.

Ari Good, JD LLM, a tax, aviation and entertainment lawyer, is the Shareholder of Good Attorneys At Law, P.A.  Ari Mr. Good received his BA, With Distinction, from the University of Michigan in 1993.  He graduated from the DePaul University College of Law in 1997 and received his LL.M. in Taxation from the University of Florida.  Ari represents DJs, live musicians, fashion models and other entertainers in copyright, licensing and contract matters.

Image by Wootang01

Royalty Free Samples: A Peculiar Problem of Producing Music

A common question from DJs and music producers is: “what right do I have to create and protect my own music using ‘royalty free’ samples, beats, and loops?”  Can you copyright work that you derive from these sources?  The simple answer is yes, if certain requirements are met.  This situation is a textbook example of derivative works and rights (one of the six exclusive rights of copyright).  Artists can copyright derivative musical works as long as they had the necessary permission to use the original source material.  Let’s break down the issue in detail:

Royalty Free
DJ Equipment

1.      The source material must be “royalty free”, or really, “royalties paid”, for you to use them in your own music.

 

As a refresher, there are typically two parties in music business who own the bundle of rights we call “copyright” and would want a royalty if their music is used.  The first are the owners of the musical compositions themselves (the arrangement, lyrics, etc.), typically music publishing companies, who have purchased these rights from the original musicians.  The second are the owners of the master recordings, typically the record labels.

Say, for example, you wanted to use a sample from the Rolling Stones song Shattered from their studio album, Some Girls (and who wouldn’t?).  You would need to obtain permission from (and pay royalties to): (1) the Rolling Stones’ music publisher, for the music composition, and (2) the Rolling Stones’ record label, for the master rights to the recording.  (Quiz: if you recorded your own version of Shattered, you would only need to obtain permission from the Rolling Stones’ music publisher, since the master recording is no longer involved).

Now, in the case of commercially available loops and samples, it’s usually a bit of a misnomer that samples you purchase are royalty free.  Rather, the company offering the loops has paid the necessary royalty or royalties that allows them to copy and resell the loops to you.  You, as the loop buyer, may then use the loops to create derivative works.  Getting beyond use, however, requires some additional steps.

2.      In order to protect your new creation, the loop seller’s terms and conditions must grant you the right not only to use and make derivative works, but also to copy the royalty free source material.

 

You must have permission to copy and prepare derivative works from royalty free source material before you can copyright your new creation. The following is an example of terms and conditions that give you the right to use your loops to create derivative works and copy the material into your own, protectable creation:

The Sounds remain the property of its manufacturer and/or Loopmasters Limited. (Collectively, “Licensor”) and are licensed to you as the original end-user (“Licensee”), for use subject to the provisions below. All rights not expressly granted herein are reserved exclusively by Licensor.

The Sounds in a category of ‘Sample Pack’:

1.  The Licensee may use the Sounds in combination with other sounds in music productions (which include soundtracks of such as films, video productions, radio/TV programs or commercials, computer games and multimedia presentations, library music), public performances, and other reasonable musical purposes within musical compositions.

English:  You can use the loops in multiple ways, when combined with other music.

2.  The Licensee may modify the Sounds and may use the Sounds for commercial purposes as part of a musical composition with other sounds.

English:  You can alter the loops and use them in your own musical creations.

3.  The Licensee MAY NOT use the Sounds in isolation as sound effects (i.e. a sequence of musical events) or within any competitive products that are sold or relicensed to multiple third parties.  In these scenarios, the Licensee must arrange an extension with Loopmasters Limited.

English: You can’t just take our loops, then turn around and use them other than as something of your own.  Also, you can’t just turn around and resell our loops again without talking to us first.

4.  A right to use the sounds is granted only to the Licensee and is NOT transferable. This license expressly forbids resale, re-licensing or other distribution of the Sounds, either as they exist or any modification thereof. You cannot sell, loan, rent, lease, assign, upload to or download from any server, or transfer all or any of the enclosed sounds to another user, or for use in any competitive product.

English: Only you, not others, can use the loops.

5.  Licensor will not be responsible if the sounds does not fit the particular purpose of the Licensee.

English: If you’re not happy with the loops, tough luck.

PLEASE NOTE:

This is a general licence which covers all Loopmasters products, it may not apply to products from other labels that we represent at Loopmasters.com – if in doubt please email us or contact the label directly.

English: If you’re unsure that you’re using the loops properly, ask before that use.

You can only copyright musical derivative works if you have the necessary license for the royalty free source material.

3.      The musical derivative work must be substantially different from the royalty free source material.

 

Although it’s common sense, a work must be noticeably different from the royalty free source material to be derivative.  A purchased music sample is not a derivative work unless you somehow alter, transform, or adapt it.  This is usually not a problem for DJs, who may merge multiple samples or layer their own musical ideas over the sample.  Even the act of arranging different samples in a unique way is enough.  Your editorial idea for the arrangement is the added element making it a new, derivative work.

You can only copyright derivative works if they are substantially different from the royalty free source material.

4.      Derivative works do not have copyright over the royalty free source material.

 

It’s worth noting that creating a derivative work from royalty free samples, drum beats, or loops doesn’t give you copyright to the source material.  You don’t become free to do whatever you want with the source material once you create a derivative work.  This means that you can’t sell, give away, or publicly play the source material as a stand alone.  Your rights to the source material only cover its use in your new creation.

If you have any questions about royalty free music that were not discussed, leave a comment and I’ll respond.

 

–          Ari Good, Esq.

Ari Good, JD LLM, a tax, aviation and entertainment lawyer, is the Shareholder of Good Attorneys At Law, P.A.  Ari Mr. Good received his BA, With Distinction, from the University of Michigan in 1993.  He graduated from the DePaul University College of Law in 1997 and received his LL.M. in Taxation from the University of Florida.  Ari represents DJs, live musicians, fashion models and other entertainers in copyright, licensing and contract matters.

Image by BeingAgentMom

The Six Rights of Copyright – Part III: The Right to Prepare Derivative Works

This is the third part in our series on what makes a copyright.  If you’re just jumping in, take a look at the first two parts linked below to get caught up.  To refresh, the six parts of copyright are:

  • The right to reproduce the copyrighted work
  • The right to prepare derivative works based upon the work
  • The right to distribute copies of the work to the public
  • The right to publicly perform the copyrighted work
  • The right to publicly display the copyrighted work
  • (sound recording only) The right to digitally transmit to publicly perform the copyrighted work

To try to get behind the curtain of copyright, we’re individually exploring each of these six rights.  An understanding of each of these rights and how they operate will allow you, the creator, to be in a better position to take advantage of your copyright.

There are a couple words of caution.  First, the practical effect of these exclusive rights will depend on the type of copyrighted work (literary works, musical works, motion pictures, sound recordings, etc.).  Second, these are exclusive rights.  The law allows only the copyright holder to exercise these rights.

III.  The Right to Prepare Derivative Works

A derivative work starts with a pre-existing, copyrighted work.  A different author then recasts, transforms, or adapts it to create something new and original.  The exclusive right to prepare derivative works is also known as the adaptation right.  As an exclusive right, the copyright owner of the pre-existing work alone has authority to prepare derivative works.  Derivative rights also tend to overlap with the reproduction right because you’re reproducing a part of the original in the derivative work.  The derivative right exists primarily to prevent others from stealing your ideas for their gain.  It also works, however, to stop others from changing the meaning of an original work unless they have the author’s permission.

Derivative Rights
Mona Lisa with a Moustache – A Derivative Work

Derivative works come in many shapes and forms.  Mona Lisa with a Moustache is a famous scholarly example, but films from Harry Potter to the Godfather are ripped from the pages of books.  Hip hop is rife with beats, samples, and lyrics taken from earlier songs (although this musical practice has been going on for ages).  Even the popular Ecards with sarcastic messages on Facebook are derivative works.  Adaption may also occur when there is a:

      • Translation
        • Dramatization
  • Fictionalization
  • Editorial revisions
  • Annotations
  • Elaborations
  • Abridgment

Compilations (musical or factual) are NOT derivative works, but can still enjoy copyright protection under a different part of the law.

Copyright protection extends to derivative works, just as it does to the original work.  This protection, however, only covers the new and original material added to a pre-existing work. There must also be a substantial difference between the new and original work.  Creating a derivative work doesn’t give that creator any ownership over the original work.  It also doesn’t enlarge or extend the copyright protection of the original work.  The following is an example to illustrate the point:

Mario Puzzo originally penned The Godfather as a book in 1962 by Mario Puzzo.  The book Godfather has copyright protection.  Francis Ford Coppala and Mr. Puzzo took this pre-existing work, with Mr. Puzzo’s permission, and adapted it into a screenplay.  The screenplay Godfather also has copyright protection as a derivative work, but only for the new and original material.  Mr. Coppala did not gain ownership rights to the book, and Mr. Puzzo did not get added time for his copyright to the book.  The 1972 movie Godfather, in turn, was a derivative work of the pre-existing screenplay with its own copyright protection.  The two Godfather sequels also were derivative works of screenplays (these screenplays also being derivative works of the original Godfather film).

Derivative works are very common to the entertainment industry.  We could create an equally complex scenario as the Godfather example above for many musical works.

As a finale note, people can potentially invade your right to prepare derivative if they’re making Fair Use of your copyrighted work.  In plain English, people can make limited, derivative copies of pre-existing works if it’s legitimately done for educational, commentary, criticism, parody, or other similar reasons.  Technically speaking, Mona Lisa with a Moustache would be a potential example of a parody that is also fair use (if copyright protected the original Mona Lisa).

The world of derivative works is an extraordinarily complex area of law and this article only touches upon its diversity.  Artists file lawsuits everyday claiming copyright infringement and derivative rights are a big part of the reason.  Just ask the label for the Harlem Shake.

What other current and popular work out there can you think that may violate a creator’s derivative right?

–          Ari Good, Esq.

Ari Good, JD LLM, a tax, aviation and entertainment lawyer, is the Shareholder of Good Attorneys At Law, P.A.  Ari Mr. Good received his BA, With Distinction, from the University of Michigan in 1993.  He graduated from the DePaul University College of Law in 1997 and received his LL.M. in Taxation from the University of Florida.  Ari represents DJs, live musicians, fashion models and other entertainers in copyright, licensing and contract matters.