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In simple terms, you keep more working capital during the tour while staying compliant. The IRS confirms this purpose, the parties to the agreement, and the requirement to file a timely return for the covered year.
You will still need discipline. The IRS deadline is firm. Your application must arrive no later than 45 days before the first covered event (the day of the event itself is not counted in the 45, so plan backward from at least 46 calendar days out to leave a safety margin). The Service says late applications are not processed. Plan backward from opening night and build your file early.
Key Takeaways
- A Central Withholding Agreement replaces default 30% gross withholding with withholding on projected net income at graduated rates for nonresident artists and athletes.
- The application uses Form 13930 and is due at least 45 days before the first covered event. Late applications are denied.
- You apply by fax or mail. The IRS may invite you to upload supporting documents through its secure Document Upload Tool after your case is opened.
- The designated withholding agent must enroll in EFTPS with an EIN and make deposits to the Form 1042 account, then file Forms 1042 and 1042‑S.
- As of 2025, the IRS has temporarily waived the $10,000 minimum income rule and notes that Form 13930‑A is unavailable. If you project under $10,000 in U.S. gross, you may still apply using Form 13930 while the waiver stands.
Who this guide helps
- Tour and business managers supporting nonresident artists and athletes
- CPA and EA firms that prepare 1040NRs and 1042‑S reporting
- Promoters and payers who must withhold, deposit, and report correctly
If you run an accounting firm, this is also an operations topic. Most firms do not struggle because they cannot sell. They struggle when delivery breaks under season spikes, reviews pile up, and deadlines slip. A repeatable CWA workflow reduces last‑minute fire drills and protects review time.
What a CWA Actually Does
From blunt withholding to net‑based deposits
By default, U.S. payers must withhold 30% of gross U.S. payments to nonresident performers. With a CWA in place, withholding is based on estimated net income at graduated rates, usually much lower than 30% of gross. You still file the tax return at year end, and the IRS will not allow withholding to dip below your anticipated tax.
The legal footing in plain English
Two authorities sit behind the program. First, Treasury regulations under section 1441 specifically allow withholding agreements for personal services. Second, the IRS implements the program through longstanding administrative procedures. In short, the IRS may enter into a written agreement with the nonresident individual to set tour‑specific withholding, and the agreement takes effect only after all three parties sign.
Eligibility, IDs, and the $10,000 Question
Who can apply
You can apply if you are a nonresident alien artist or athlete performing independent personal services in the United States, you are current on required U.S. returns, you have arranged to pay any balances due, you have a designated withholding agent, and you have agreements for the covered events. Note that every NRA in the touring party must individually apply – band members, back-up singers, and back-up musicians included, regardless of whether they share in the tour's profits. The IRS lays out these points clearly.
SSN, ITIN, and practical reality
The IRS encourages performers who enter the United States to apply for an SSN, since it simplifies taxpayer identification. That said, IRS internal guidance recognizes that not every applicant can provide a TIN at the moment of application. Practically, you should provide an SSN or ITIN when available, or evidence that an application is in process, and keep identification consistent across all forms and contracts.
Do not let the TIN question stall your case. Apply for the SSN once you are in the U.S., or document your ITIN situation, then keep the file moving with consistent IDs across the application, budgets, and contracts.
Is Form 13930‑A still a thing
Here is the current position. The IRS temporarily waived the $10,000 minimum income requirement for Form 13930, and Form 13930‑A is currently unavailable. While that waiver is in effect, even if projected U.S. gross is under $10,000, you can apply using Form 13930. Always verify the latest note in Publication 515 before you file, since it is updated annually.
Deadlines you cannot miss
- File the application at least 45 days before the first covered event. Late filings are not processed.
- Plan for separate applications if your itinerary spans calendar years.
- Expect a Tax Specialist to contact you within 3 business days of assignment regarding the status of your application and any additional information required.
How to submit in 2025
- Initial application route. Send Form 13930 and the core packet by fax or mail to the CWA Program. The IRS lists the fax number and mailing address, and it states that late applications will not be processed.
- Secure uploads after contact. Once the IRS issues an access code or requests information, you can use the Document Upload Tool to send PDFs or images securely through your browser. This reduces back‑and‑forth and speeds reviews.
The Three Parties and Their Jobs
You, the performer or your representative
- Provide contracts, itinerary, and a realistic budget.
- Stay current on past filings, or document arrangements to pay.
- Commit to filing a Form 1040NR for the covered year.
The designated withholding agent
- Must be the person that controls, receives, or pays U.S. income, and must be an independent third party unrelated to the performer – an NRA cannot serve as their own withholding agent, nor can a personal LLC or other related-party entity fill the role.
- Enrolls in EFTPS using an EIN and makes Form 1042 deposits on time.
- Files Forms 1042 and 1042‑S reporting the payments and withholding for the covered period.
The IRS
- Reviews eligibility and documentation.
- Issues the agreement for signatures.
- May request updates as facts change and can modify or revoke if terms are not followed.
What To Include in a Clean, Approval‑Ready File
The working checklist
- Signed Form 13930, penalty‑of‑perjury statement, and authorization if represented, using Form 2848 or 8821.
- Full contracts and deal memos for every U.S. event, plus sponsor and endorsement schedules if covered.
- A practical, itemized budget, including travel, lodging, per diems, production, agent and manager fees, and crew.
- A dated itinerary with cities, venues, and expected gross.
- Identification details, including SSN or ITIN if available, or proof of application in process.
- Withholding agent info, EIN, and EFTPS readiness.
The IRS needs enough detail to tie income streams to events and to see how deductible costs drive projected net income. A tight budget and complete contracts speed review.
A quick thresholds table for context
| Requirement | Today’s status | Why it matters |
| Income threshold to use 13930‑A | 13930‑A is currently unavailable | Apply with Form 13930 even if under $10,000 while waiver stands. |
| Timing | File at least 45 days before first event | Late filings are not processed. |
| Deposits | EIN required, deposits via EFTPS to Form 1042 | Withholding agent responsibility. |
| Year‑end returns | File 1040NR and 1042/1042‑S | You true‑up at filing. |
Net‑based withholding in practice
- You project gross receipts per event, subtract allowable U.S. expenses, and compute estimated net income.
- The agreement sets deposit amounts and dates that match the schedule of payments.
- Withholding is based on graduated rates and cannot be lower than anticipated tax.
Where state taxes fit
A federal CWA does not automatically cover state withholding. Coordinate early with state rules for performances in those jurisdictions. Use the federal allocation as your starting point, then follow state‑specific deposits and returns. The IRS reminds withholding agents that absent a CWA, they must withhold at statutory rates, typically 30% for independent personal services. States may impose their own obligations.
Step‑by‑Step, From First Call To First Show
1) Scope the itinerary and budget
Start with the events, contracts, and realistic costs. Tie every dollar to a document. That single discipline shortens review time and reduces revisions.
2) Choose the withholding agent
Pick the person or entity that actually pays or controls tour income in the U.S. – they must be an independent third party, not the NRA or a related entity. Confirm they have an EIN and enroll them in EFTPS as a business so they can make Form 1042 deposits on schedule.
3) File Form 13930 on time
Send the application by fax or mail no later than 45 days before the first covered event. Track delivery, then watch for the IRS confirmation and any request for more information. If the IRS gives you an access code, use the Document Upload Tool to push additional PDFs quickly and securely.
4) Sign and follow the agreement
When the IRS approves and issues the CWA, everyone signs. The agreement is effective when all parties have signed. From that point, the withholding agent must deposit per schedule to the Form 1042 account through EFTPS and later file Forms 1042 and 1042‑S. After the tour wraps, the withholding agent also has to provide a final accounting comparing actual income and expenses to the CWA budget and deposit any additional withholding tax owed – a CWA is not a set-and-forget arrangement. The performer must file Form 1040NR for the year.
5) Keep the agreement current
Tours change. If dates, fees, or expenses shift, tell the IRS promptly. The Service can modify or revoke the agreement if facts change or terms are not met.
Example, how the numbers shift
- Without a CWA. A $500,000 U.S. gross would trigger $150,000 withheld at 30%.
- With a CWA. Suppose allowable U.S. tour expenses are $320,000, projected net is $180,000, and graduated rates apply. The deposit schedule would track those payments, and total deposits would target the anticipated liability, not a flat $150,000. The IRS is explicit that a CWA cannot reduce deposits below the anticipated tax.
Common tripwires that get cases denied
- Filing inside the 45‑day window. The IRS will not process late applications.
- Missing core docs. No itinerary, no budget, no contracts.
- No eligible withholding agent, or no EIN and EFTPS enrollment.
- Prior returns not filed or balances not arranged.
- Inconsistent identity data across forms and contracts. The IRS checks.
Treat the CWA like a live engagement. Build a clean book, assign an accountable lead, and track every dependency. That is how you avoid last‑minute denials.
Quick reference, who files what
| Role | What they file | When |
| Withholding agent | Form 1042 deposits via EFTPS, then Forms 1042 and 1042‑S | Per the CWA schedule and by annual deadlines |
| Performer | Form 1040NR for the covered year | By the standard nonresident deadlines, or extended if applicable |
Compliance guardrails you should know
- The regulation allows the IRS to enter withholding agreements for personal services. The agreement is effective only after all parties sign.
- Absent a reliable agreement, payers must withhold at statutory rates, generally 30% on independent personal services.
- The IRS will not accept applications inside 45 days of the first event. Build the timeline backward.
The simplest way to keep momentum is to treat the CWA package like a show advance. Confirm the who, what, when, and how on paper, then ship it before the 45‑day mark.
Final pointers and a simple CTA
- Calendar the 45‑day deadline, then work backward with internal milestones.
- Do not wait on the SSN to start, document the TIN path and keep IDs consistent.
- Tie every dollar in the budget to a contract or a reasonable memo.
- Name a single owner for each CWA and track deposits and reporting until 1042‑S and 1040NR are filed.
If you want help turning this into a repeatable, well‑controlled process inside your firm, our team can share a checklist and review template. Book a quick session and we will walk you through a CWA kit you can deploy next week.
Common Mistakes We See Every Season
The same patterns show up year after year on CWA files, and most of them come from treating Form 13930 like a standard tax form rather than a strict 45-day submission with tight eligibility, attachment, and signatory rules.
Reusable Checklists
These checklists are written to drop straight into a firm's SOP folder or a withholding agent's tour binder. Each item maps to a step the IRS expects to see in a clean, approval-ready Form 13930 file.
Pre-submission packet
- Confirm the first event date and count back 46 calendar days to set the internal filing deadline.
- Complete Sections 1, 2, and 3 on Form 13930 (NRA, withholding agent, contact person).
- Draft the narrative letter per Revenue Procedure 89-47 with the verbatim perjury statement and a signature from the NRA or Form 2848 representative.
- Attach the line-by-line budget, separately stating U.S. income and expenses from any non-U.S. activity on the tour.
- Attach contracts, itinerary, and venue list for every covered event (6 attachment categories for entertainers, 7 for athletes).
- Disclose any prior CWAs in the same calendar year and any U.S.-source income earned that year outside a CWA.
- Confirm the withholding agent holds a U.S. bank account and is actively enrolled in EFTPS.
- Fax the full package to 1-866-715-1507 or mail to the Laguna Niguel CWA Program at 24000 Avila Road, MS 6040, Laguna Niguel, CA 92677.
Group roster and ID scan
- List every NRA performer on the tour, including band members, backup singers, dancers, and any participating crew.
- Verify each NRA has a valid SSN or ITIN; route any work-visa entry to SSA for SSN issuance if missing.
- Use the Continuation Sheet for Entertainment Groups for additional NRAs (3 slots per sheet).
- Capture date of birth, country of residence, country of citizenship, marital status, and stage name for each performer.
- Run the six-year U.S. presence look-back and clear any unfiled Form 1040NR returns before submission.
- Attach a Form 2848 or Form 8821 for any representative communicating with the IRS, covering the current-year CWA and Form 1040NR for the present and two prior years.
Post-tour reconciliation
- Pull final settlement statements for every covered event.
- Compare actual gross income, sponsorship, and merchandise revenue against the budget filed with the CWA.
- Reconcile actual expenses (travel, lodging, crew, commissions) against the corresponding budget line items.
- Recompute tax at graduated rates on the revised net-income figure.
- Deposit any additional withholding tax owed through EFTPS.
- File Form 1042 and the matching Form 1042-S for each NRA covered by the CWA.
- Confirm each NRA's Form 1040NR is filed for the tax year covered.
- If the tour crosses calendar years, confirm a separate CWA application has been filed for the second year.
Keep 13930 Season From Stalling
Form 13930 work bunches around tour calendars rather than April peaks, but the squeeze still lands hard. Every covered event triggers a fresh 45-day clock, the September 2022 instructions for Form 13930 list 6 attachment categories for entertainer files and 7 for athlete files, and the IRS Paperwork Reduction Act notice puts the average total time burden at 12 hours per application (5 hours of recordkeeping, 3 hours learning the law, 2 hours 30 minutes preparing, and 1 hour 30 minutes copying and sending).
The answer is not more hands at the last minute. It is a delivery system that treats CWA work like a defined production line: clear ownership of the 45-day clock, a standing attachment template, a withholding-agent onboarding checklist, and a post-tour reconciliation flow that runs every time without prompting.
- Maintain a master CWA tracker keyed off the first event date, with the 46-day internal deadline computed for every NRA on the roster and a daily watch on the IRS three-business-day specialist contact window.
- Standardize the narrative letter template per Revenue Procedure 89-47, including the verbatim perjury statement, the Treasury Regulation §1.1441-4(b)(3) citation, and a slot for prior-CWA disclosure in the same calendar year.
- Build the budget spreadsheet to separately state U.S. and non-U.S. income and expenses, with a checksum row that flags any tour crossing calendar years (which requires a separate CWA for each year covered).
- Run a withholding-agent readiness check before any application is signed: independent third party unrelated to the NRA, U.S. bank account, active EFTPS enrollment, and capacity to file Form 1042 and Form 1042-S.
- Schedule the post-tour reconciliation and the matching Form 1040NR filing inside the same engagement so neither falls off the calendar after the show wraps.
This is the system our taxation delivery teams stand up for CWA work: trained U.S.-led offshore staff own the 45-day clock, the attachment build, and the post-tour reconciliation under documented SOPs and turnaround SLAs, with multi-layer review steps that catch the misses before the IRS does.
FAQs
Can a CWA cover multiple tours or just one period
It can cover multiple events within the agreed scope and dates. The IRS treats the CWA as event and time specific. If your itinerary expands or shifts, communicate and expect to sign an addendum when documentation is provided in time.
Are per diems taxable under a CWA
Per diems can be treated as reimbursements when they follow federal rates and you substantiate the policy and amounts. If payments exceed allowances or lack proof, expect tax and reporting. Your budget should flag per diems clearly so the IRS can see how they were handled in projected net income.
Can minors apply with a guardian
Yes, but follow the regular CWA requirements and local legal rules on consent and representation. The IRS focuses on the tax and withholding framework. Your documentation must still show contracts, itinerary, and a compliant withholding agent.
What happens if an event gets canceled after approval
Notify the IRS and document the change. Managers can approve addenda to remove canceled events and adjust deposit schedules. Keep proof of refunds, insurance, or lack thereof.
How do federal and state withholding interact
The federal CWA governs federal deposits and reporting. You still need to comply with each state’s rules for performances there. Start with your federal allocation, then follow state guidance for deposits and credits.