Tax counsel for content creators.
Self-employment tax, brand-deal characterization, platform 1099 mismatches, multi-state issues for creators who tour or relocate, and privacy-aware structuring. Under §183, the nine-factor profit-motive test treats personal enjoyment as evidence against business intent, which is a structural problem when your persona is the business.
Start with your situationOnlyFans creator? There is a dedicated page for your situation.
Self-employment tax and entity choice
Platform income is self-employment income, and the structure you file under affects the tax. The right entity and election depend on your revenue mix and how much of it runs through platforms versus brand deals.
Brand deals and the §183 problem
The profit-motive test treats personal pleasure as a strike against business intent. For a creator whose life is the product, the documentation has to affirmatively show business purpose. My Bloomberg Tax piece walks through what that paperwork looks like.
Events, experiences, and paid promotion
Premieres, galas, meet-and-greets, trips, follower-growth services. Some of it is deductible and a lot of it is not, and the line is not whether it helped your numbers. In August the Tax Court ruled on an influencer's spending for the first time, and it drew that line hard. What the court said.
Platform 1099 mismatches
When the numbers on your platform 1099s do not match what hit your bank, the IRS sees the gap before you do. The fix is reconciliation that holds up, not a return that hopes the question never comes.
Multi-state and privacy-aware structuring
Creators who tour or relocate pick up filing obligations in multiple states, and many have real reasons to keep their legal name and address off public filings. Both are solvable with deliberate structuring.
In Sami v. Commissioner, T.C. Memo. 2026-69 (August 18, 2026), a New York taxpayer who described himself as an influencer with hundreds of thousands of followers deducted tickets to the Grammys and the Emmys, paid meet-and-greets with actors, and the chance to catch a pass from Tom Brady (he dropped it) as marketing for his social media business. The court noted it had never before applied the business expense rules to an influencer's spending, then disallowed all of it. It is a memorandum opinion, so it is not binding precedent. It is also the only thing the court has said on the subject, which makes it the starting point for any examiner looking at a creator's return.
"Did it help" is not the test
The influencer argued the celebrity content grew his views and followers. The court's answer: "the question is not whether the expenses had any effect on revenues." An expense has to be primarily for business, and the court started from the premise that people pay for experiences like these for their own enjoyment and status. The court also rejected the argument that this is normal spending for influencers. Even typical influencer expenses fail if the primary motive was personal. For a creator whose life is the content, this is the central problem, and the answer is documenting business purpose when you spend, not arguing it later.
How you treated it at the time counts
He originally deducted the same payments as charitable contributions and only called them marketing at trial. The court read that as evidence of what they really were. The label you choose when you pay, in your books and on your return, is part of the proof.
No revenue yet is its own problem
He had no income from influencing in the years at issue. The court flagged that even legitimate spending on a line of business that is not yet producing revenue likely counts as startup costs, which cannot be deducted in full as incurred. Generally up to $5,000 is deductible in the year the business begins, with the rest spread over 15 years. Creators who spend heavily before monetizing need to plan for that.
Paid promotion lost on proof, not on principle
His follower-growth services and "general marketing" were disallowed because bank statement lines with PayPal usernames and merchant codes did not show what he bought or why. The court did not say paying to promote an account can never be deducted. Keep the invoice, what the campaign was, and what it promoted.
Records decided every line
Where he had contemporaneous records, he won. His handwritten trip vouchers got 80% of his car expenses allowed despite estimated mileage, though partly because his cars carried passengers for hire, which exempted them from strict substantiation rules that apply to most people's vehicles, including most creators'. Four phones with no business-use records got 25% on an estimate. Streaming subscriptions claimed as "market research" were personal. And running business and personal spending through the same cards undercut everything he could not prove some other way.
Sophistication cuts against you
He had two accounting degrees and kept no books. The court held that someone with his background knew better, and sustained 20% accuracy penalties on every year. The reasonable-cause defense is built on what a person in your position should have understood.
Can influencers deduct events and experiences?
Only if the expense is primarily for business, and the Tax Court starts from the premise that people buy experiences like these for enjoyment. Content you create there does not change that on its own. Document the business purpose at the time: the campaign, the brand deal, the deliverable.
Can I deduct paid promotion or follower-growth services?
Promotion can be a business expense. Proof is the problem. A bank line with a username is not evidence of what you bought. Keep invoices and a record of what each payment promoted.
Can I deduct streaming subscriptions as research?
Rarely. The Tax Court treated them as personal because watching TV is ordinary personal consumption, even when claimed as research for an entertainment-related business.
I have not made money yet. Can I deduct what I spend?
Maybe not right away. Spending before a business is active is generally a startup cost: up to $5,000 deductible in the first year, the rest over 15 years. Where the line falls between hobby, startup, and active business is worth getting right early.
What records do I actually need?
A separate business account and card, receipts or invoices that say what was bought, and a note of the business purpose made when you spend. Where Sami had records like that, he won. Where he had only statement lines, he lost everything.
Have one of these situations right now?
If there's a notice with a deadline on it, that deadline is what matters most. Tell me what's going on.
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