About the Course
Introduction
This CLE/CPE webinar will provide tax professionals guidance on the key tax considerations for student-athlete name, image, and likeness (NIL) deals and NIL collectives. The panel will discuss the applicable rules and regulations for NIL deals and entities engaging in these transactions, federal and state tax challenges, reporting requirements, and tax planning for student-athletes. The panel will also discuss the tax implications for NIL collectives in college sports, for both athletes and universities, for-profit entities and those that obtained tax-exempt 501(c)(3) status, and other issues.
Description
In National Collegiate Athletic Association v. Alston (U.S. 2021), the Supreme Court unanimously ruled that NCAA rules limiting member institutions from providing student-athletes with education-related benefits and awards violated federal antitrust law. Shortly thereafter, the NCAA suspended its restrictions on student-athletes receiving compensation related to their NIL, which opened up substantial financial opportunities for student-athletes. Those executing NIL agreements face significant federal and state tax implications, including income tax responsibilities, state nexus, and reporting obligations.
Under the NCAA rules, student-athletes can be compensated for endorsements without putting their NCAA eligibility at risk, but other forms of payment remain prohibited. As a result, many student-athletes receive monetary compensation and/or goods by entering into contracts to promote and market their NIL.
Generally, both monetary and non-monetary compensation are considered taxable income. This forces student-athletes to consider the tax implications, reporting requirements, and available tax planning options if they are benefiting from their NIL. Tax advisers for companies, universities, and athletes must keep in mind the various federal and state tax issues as well as potential issues stemming from NIL agreements.
Listen as our authoritative panel examines applicable rules and regulations for NIL deals and entities engaging in these transactions, federal and state tax challenges, reporting requirements, and tax planning for student-athletes. The panel will also discuss the tax implications for NIL collectives in college sports and those with tax-exempt 501(c)(3) status, and other issues.
Presented By
Mr. Frieser is a nationally recognized sports business lawyer and Principal Attorney at Frieser Legal. His practice is focused on the representation of athletes, agents, and sports businesses. While working to solve the unique legal needs that they have, Mr. Frieser represents athletes in eligibility and disciplinary proceedings and NIL licensing agreements, as well as in related intellectual property and business planning matters. In addition to serving as counsel to college and professional athletes, he represents sports agents and sports industry ventures as outside counsel. Mr. Frieser is a leading expert on the regulatory landscape of college athletics, he has been quoted in numerous publications, including the Associated Press, Front Office Sports, and the Wisconsin State Journal. Mr. Frieser's written work has been featured by Sports Law Expert and The NIL Deal. He also regularly speaks on panels and CLE seminars about NIL and the legal implications surrounding college sports.
Mr. Madden is the founder of Thad Madden Tax Consulting. He retired from the IRS
after a 38-year career as a revenue officer, analyst, and program manager. One of Mr. Madden's final projects was helping lead an agency-wide task force that examined compliance rates for college athletes being paid under the banner of name, image, and likeness. In his consulting role, he represents taxpayers, serves as in-house tax expert for Scout, a financial technology company focusing on athletes, and as a certified service provider with Athletes.org.
Mr. Milton started his career as a Trial Attorney with the Department of Justice Tax Division, in Washington, DC, via the prestigious Attorney General’s Honors Program. While with the DOJ, he represented the IRS in various collection matters, refund suits, and complex tax cases in federal courts throughout the United States. In 2014, Mr. Milton was awarded the DOJ’s Outstanding Trial Attorney Award. Prior to founding Milton Law Group, he worked at an AmTop100 law firm in St. Louis specializing in tax controversies, white collar criminal defense, health care and securities fraud defense, corporate internal investigations, and business litigation for small businesses and Fortune 500 companies. Combining his intimate knowledge of how the IRS operates based on his Department of Justice experience and the elite representation he’s provided to Fortune 500 companies, Mr. Milton is able to merge the best of both worlds to provide trusted legal representation to individuals and small businesses.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Tuesday, July 21, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. NIL regulations and policies
A. Recent cases
B. NCAA rules
C. State laws and school policies
II. NIL collectives
A. How are they structured?
B. Regulatory framework
C. Tax-exempt NIL collectives
III. Tax considerations for student-athletes
IV. Federal tax considerations
V. Sponsorship and service income
VI. Cash awards
VII. Royalty income
A. Impact on financial aid
B. State tax implications
VIII. Best practices for counsel and advisers structuring NIL agreements
The panel will discuss these and other key issues:
- Types of NIL deals and key tax considerations for student-athletes, universities, and companies
- Best practices for attorneys and advisers structuring student-athlete-involved NIL agreements
- Navigating the federal tax rules, reporting requirements, and available tax planning strategies
- NIL collectives and special rules governing tax-exempt NIL collectives
- Key state tax considerations for student-athletes and companies
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