NIL: Residency Matters

ABSTRACT In 2021, NCAA v. Alston gave student athletes the opportunity to compensation for their name, image, and likeness (NIL).1 Then, in 2024, the National Collegiate Athletic Association (NCAA) and the Power Conferences2 settled antitrust cases for $2.8 billion and 22 percent of Power Conferences’ average revenues.3 This paper overviews legal aspects of student athlete rights and income tax residency presumption rules and addresses the impact of NIL on students, practitioners, and state tax agencies.