There are several issues - I have produced in both countries. Certainly overseas performers working on Broadway, or other AEA productions in the USA are subject to AEA rules, and AEA minimum salaries and all the usual work rules. They have to join AEA, and pay dues, and the producer pays pension and health and annuity and vacation pay and everything else. If a production stars in the UK, and hires an American actor, AEA has no jurisdiction (even though sometimes they have been known to try and assert it). The producer in the UK negotiates with an actor (via agent) for a UK salary, with all UK conditions, taxation etc applying.
On the other hand, if, as an example, the BRoadfway production of PIANO LESSON were to go to the West End with its whole cast, etc, then AEA, SDC et al WOULD exert jurisdiction, and those actors and artists would be working on US union rates and terms, or close to them.
As an example in practice, we took a US choreographer to London work on a UK musical. We negotiated a contract etc. The artist in question asked if there were any way we could pay into SDC Pension & Health on their behalf. We spoke with SDC, who clearly told us that as the production was UK in origin they had no jurisdiction. We could not pay into SDC pension/health, and SDC coudnt issue a contract for a member for a UK origin production as a way to allow pension and health. No jurisdiction. |
