The amount of the advanceroyalty payment generally is subject to U.S. tax in the year received (but there would be no further taxable royalty income in years 2 and 3).
FORBES: Corporations Can Prepay Royalties To Access Foreign Cash
2.
When most artists sign record deals, they hand over these rights in exchange for an advance payment, a smaller royalty of 10-15% on music sales and the prestige of recording an album for a major record label.