NIL: Residency Matters Available to Purchase

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.