John Woods is a successful professional tennis player. He is a resident of Hong Kong. John plays tournaments around the world, about one-half of which are in the United States. Woods's reputation is a role model for young tennis players.He comes to you with several Federal income tax questions.How does U.S. tax law affect Woods for the following items? Would it matter if he moves to the United Kingdom.

Endorsement income from Tennispro for wearing clothing during matches with its logo prominently displayed. Woods must play in at least 10 tournaments per year that are televised around the world. Payment to Woods is structured as a flat fee, with bonuses paid if he finishes in the top ten competitors for each match. This is known as an on-court endorsement.

His winnings from tournaments that he plays in the United States.

Endorsement income from ProTennis for letting the company use his likeness in a video game that simulates tennis tournaments among players that the gamers identify with. In this way, the gamer seems to be playing against Woods on famous tennis courses. Two-thirds of all dollar sales of the game licenses are to U.S. customers.

Endorsement income from TennisMade for appearing in print and internet ads that feature Woods wearing the company's high-end watches. One-fifth of all dollar sales of the watches are to U.S. customers. The latter two items are known asoff-court endorsements.