Law Watch

We watch the law so every plan you send is current.

Federal, state, and NCAA rules that touch NIL and revenue-share income change constantly. Our monitoring agents track the primary sources; nothing reaches a client plan until a human reviews and approves it. This is that public record.

Current as of Jun 23, 2026
Critical Action may be neededUpdate Informational
  1. Jun 23, 2026
    Live in plans
    UpdateNCAA · Eligibility

    NCAA approves age-based five-year eligibility rule

    The NCAA adopted a model granting five years of eligibility to be completed within five years of high-school graduation — or an athlete's 19th birthday, whichever comes first — eliminating redshirts and replacing the old 'five years to play four.' Limited exceptions apply (military service, religious mission, maternity), and current student-athletes have until July 31 to request hardship waivers. Not a tax change, but it resets the NIL and revenue-share earning window — the horizon every multi-year tax plan is built on.

    Who it's affected: Athletes whose earning window — and multi-year planning horizon — shifts under the age-based clockSource: CBS Sports — NCAA votes to approve age-based five-year eligibility rule
  2. Jun 12, 2026
    Live in plans
    UpdateFederal

    Social Security wage base rises to $184,500 for 2026

    Up from $176,100. Raises the FICA ceiling on S-Corp salaries above the base, so the reasonable-comp salary on high earners now carries slightly more payroll tax — the S-Corp savings math is recomputed automatically.

    Who it's affected: High-salary athletes (reasonable-comp salary above the wage base)Source: SSA 2026 COLA fact sheet
  3. May 28, 2026
    Held for review — not yet applied
    CriticalNCAA · Revenue share

    Employment-status challenge advances in appellate court

    A ruling could reclassify revenue-share pay as W-2 wages — which cannot be routed through an S-Corp and would not qualify for QBI. If it lands, the core strategy for revenue-share athletes changes overnight. Held for legal review; no change applied yet, but every affected plan is flagged.

    Who it's affected: Every athlete taking school revenue shareSource: Johnson v. NCAA (athlete employment status) · Sportico
  4. Apr 30, 2026
    Held for review — not yet applied
    CriticalNCAA · House settlement

    House settlement payments: 1099 treatment reaffirmed for the 2025–26 cap year — but contested

    Schools are reporting first-year revenue-share distributions on Form 1099, keeping the S-Corp and QBI strategy live for active-service classification. Two practitioner groups have asked Treasury for a W-2 ruling. We model 1099 today and will switch plans the moment guidance changes.

    Who it's affected: Athletes receiving direct school revenue-share paymentsSource: House v. NCAA settlement — revenue-share framework · Sportico
  5. Apr 28, 2026
    Held for review — not yet applied
    UpdateInternational · Treaty

    U.S.–Croatia tax treaty advances by protocol — but is still not in force

    The first-ever U.S.–Croatia income-tax treaty (signed 2022) was amended by a protocol on April 28, 2026 to align with the One Big Beautiful Bill Act, clearing the way for transmission to the U.S. Senate. It has NOT entered into force and still awaits Senate advice and consent to ratification. Until then, Croatian athletes have no U.S. treaty benefits and remain at the 30% no-treaty FDAP rate — we'll switch the modeled rate the moment it is ratified.

    Who it's affected: Croatian athletes — no U.S. treaty rate until ratification (currently the 30% no-treaty default)Source: U.S. Treasury — United States, Croatia sign protocol to income tax treaty
  6. Apr 9, 2026
    Live in plans
    UpdateFederal · NIL

    Executive order: "Urgent National Action To Save College Sports"

    A presidential executive order on college sports was published in the Federal Register. It signals federal-level action on the NIL and revenue-share landscape — read the official document for the specific directives. Surfaced by the monitoring agents from the Federal Register; informational watch, no plan change applied.

    Who it's affected: The federal NIL / college-sports regulatory environment (all athletes)Source: Federal Register — Executive Office of the President
  7. Feb 4, 2026
    Live in plans
    UpdateFederal

    1099 reporting threshold rises from $600 to $2,000

    Fewer small NIL deals trigger a 1099 in 2026. This changes reporting, not tax owed — income is still taxable below the threshold. Affects which third-party deals generate paperwork.

    Who it's affected: Athletes with many small third-party NIL dealsSource: IRS — General Instructions for Certain Information Returns
  8. Jan 15, 2026
    Live in plans
    UpdateState

    North Carolina flat rate drops to 3.99% for 2026

    Down from 4.25%. Lowers state tax for all NC-resident athletes and slightly shifts the multi-state allocation math for road games played outside NC.

    Who it's affected: North Carolina residentsSource: NC Department of Revenue
  9. Dec 9, 2025
    Live in plans
    UpdateState · PTET

    California extends its Pass-Through Entity Tax election through 2026

    California's PTET — which lets an S-Corp deduct state tax federally and sidestep the SALT cap — remains available for the 2026 tax year. For high-earning CA-resident athletes electing S-Corp, this is one of the largest single federal deductions in the plan.

    Who it's affected: California-resident athletes electing S-CorpSource: CA FTB · AB-150 extension
  10. Nov 20, 2025
    Live in plans
    UpdateFederal · Retirement

    2026 Solo 401(k) limits increase: $24,500 deferral, $72,000 total additions

    The elective-deferral limit rises to $24,500 and the §415(c) annual-additions cap to $72,000 for 2026. More room to defer earnings tax-free under either entity — the optimizer now sizes employer profit-sharing to the new ceiling.

    Who it's affected: Every athlete funding a Solo 401(k)Source: IRS Notice — 2026 retirement plan limits
  11. Oct 2, 2025
    Live in plans
    UpdateFederal · Audit

    IRS signals heightened scrutiny of §280A(g) 'Augusta Rule' deductions

    Examiners are challenging home-rental deductions taken without written agreements or fair-market comps. The deduction is still valid — but the guardrails now require documentation and a defensible daily rate before the plan recommends it.

    Who it's affected: S-Corp athletes using the Augusta RuleSource: IRS Topic No. 415 — Renting residential property (§280A 14-day rule)
  12. Feb 1, 2024
    Live in plans
    UpdateInternational · Treaty

    U.S.–Chile income-tax treaty entered into force

    The first new U.S. bilateral income-tax treaty in over a decade entered into force on December 19, 2023, and took effect for withholding taxes on amounts paid or credited on or after February 1, 2024. Chilean athletes gain treaty access — reduced withholding on qualifying U.S.-source royalty/FDAP income versus the 30% no-treaty default, subject to the treaty's limitation-on-benefits terms. Verify the specific article and rate against IRS Pub 901 before relying on it.

    Who it's affected: Chilean athletes with U.S.-source NIL income (new reduced treaty rates)Source: IRS — Chile tax treaty documents
  13. Jan 15, 2024
    Held for review — not yet applied
    CriticalInternational · Visa

    F-1 / J-1 NIL work authorization remains unresolved

    For an athlete on an F-1 or J-1 visa, the threshold question isn't the tax — it's whether the NIL activity is authorized at all. Compensated NIL work performed in the United States is generally treated as employment requiring work authorization (CPT/OPT) under the F-1 rules at 8 CFR 214.2(f); unauthorized work can jeopardize immigration status. Activity performed entirely outside the U.S. and genuinely passive licensing are the commonly cited workarounds, but the area is contested and no federal guidance has resolved it. Held as a standing guardrail — every nonresident NIL plan has to answer this first, with a licensed immigration attorney.

    Who it's affected: Every F-1 / J-1 international athlete considering U.S. NIL activitySource: USCIS — Students and Employment (F-1 work authorization)
  14. Jan 1, 2024
    Live in plans
    CriticalInternational · Treaty

    U.S.–Hungary income-tax treaty terminated — benefits ended Jan 1, 2024

    After the United States gave notice of termination, the U.S.–Hungary income-tax treaty ceased to have effect for withholding taxes on amounts paid or credited on or after January 1, 2024. Hungarian nationals lose treaty protection: U.S.-source royalty/FDAP income that might have qualified for a reduced or zero treaty rate now defaults to the full 30% withholding. Any plan built for a Hungarian athlete has to be repriced at the no-treaty rate.

    Who it's affected: Hungarian athletes with U.S.-source NIL income (treaty rate no longer available)Source: IRS — Hungary tax treaty documents (treaty terminated)
  15. Jan 1, 2024
    Live in plans
    UpdateInternational · Reporting

    1042-S electronic-filing threshold drops to 10 returns

    Under IRS final regulations, any payer required to file 10 or more information returns in aggregate must file them electronically for returns due on or after January 1, 2024 — including Form 1042-S, the form used to report U.S.-source FDAP income paid to nonresident athletes. Schools, collectives, and agencies paying international athletes need to e-file 1042-S or risk penalties.

    Who it's affected: Schools, collectives, and agencies paying U.S.-source income to nonresident athletesSource: IRS — E-file information returns (final regulations)
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