Sports
Client Alert


The approval of the House v. NCAA settlement marks a watershed moment in college athletics. In addition to $2.8 billion in back damages to former athletes unable to capitalize on the sale of their name, image, and likeness (“NIL”), the settlement allows institutions to directly compensate student-athletes, fundamentally altering the traditional model of amateurism in college sports. It also requires athletes to report NIL deals to a third-party clearinghouse run by Deloitte, and sets roster limits across sports, while grandfathering current athletes who might otherwise lose their spots. While much of the public discourse has focused on the employment and cultural ramifications of the case, the settlement also introduces (and fails to clarify) a host of complex tax issues that could affect college athletes nationwide. For a comprehensive breakdown of the House settlement in full, please see Whiteford’s recent client alert.
The settlement’s structure raises immediate questions about how these payments will be taxed, how athletes should report their income, and what new compliance burdens they may face. This alert first discusses the tax implications raised by the settlement agreement, with respect to potential audit risks that student-athletes may face in this new environment. Next, it walks through possible tax consequences related to college athlete employment status—an issue left undecided by the settlement. Lastly, it provides insight into how Whiteford’s tax expertise can help athletes, their advisors, brands, and institutions navigate these challenging issues.
- Potential Audit Risks for College Athletes to Consider
With the House v. NCAA settlement approved, the new compensation model creates a host of potential audit risks and tax complexities for college athletes. Many are now navigating a tax environment rivaling that of professional entertainers and athletes, with several income streams, cross-border issues, and heightened scrutiny from multiple tax authorities. Below are a few key audit risks that college athletes should consider.
Multi-State Tax Filing Obligations and Duty Day Rules
One of the most significant audit risks arises from the potential need to file income tax returns and pay income taxes in multiple states. College athletes receiving NIL income from brands across different states may have previously considered their potential multi-state tax-filing requirements,[1] but House’s direct revenue-sharing payments could trigger different cross-state filing obligations according to the “duty day” methodology, similar to professional sports. Generally, states that use a “duty day” methodology[2] will impose income tax on non-resident professional athletes based on the proportion of the number of days spent in the state playing games, practicing, or training compared to the athlete’s total number of duty days. Before House, college athlete compensation was not tied to their performance on the field, but rather to any nexus their NIL income had to particular states. Because House offers direct payments from universities, the performance element could open the door to new income tax filing obligations, particularly where state “duty day” statutes and regulations are ambiguous as to whether they apply to student-athletes.
A few states have proposed legislation to exempt NIL earnings from state income taxes (up to certain thresholds), but so far, only Arkansas has specifically addressed taxes related to revenue-sharing income in H.B. 1917 (amendments to the Student-Athlete Publicity Rights Act). Other states may follow suit, but until then, the complexity of multi-state filings increases the risk of errors, underreporting, and missed filing obligations, all of which can trigger audits and penalties. This is especially true if schools do not withhold income on behalf of the players. Athletes should maintain detailed travel logs and records to accurately allocate income and comply with state tax laws.
In-Kind Compensation and Valuation Challenges
Athletes are increasingly receiving in-kind benefits as part of their NIL deals, such as apparel and equipment, use of vehicles, and travel and lodging for family members, among others. The IRS generally treats the fair market value of these benefits as taxable income. However, determining the correct value can be challenging, especially for unique items.
To avoid issues down the road and meet their income tax filing and payment obligations, athletes should obtain documentation of the value of each in-kind benefit, report the value as income on their tax returns, and retain records in case of an audit. The failure to properly report in-kind compensation is a common audit trigger, and discrepancies between reported values and actual market prices can lead to additional tax assessments and penalties.
Estimated Tax Payments and Withholding Issues
Athletes classified as independent contractors may be required to make quarterly estimated tax payments to the IRS and, in many cases, to state tax authorities. Failure to make timely payments can result in underpayment penalties and interest charges. Even athletes classified as employees may face withholding issues if their schools do not accurately calculate tax obligations.
Athletes should calculate estimated tax payments based on projected income, monitor payments throughout the year to avoid shortfalls, and potentially adjust payments as income fluctuates, especially with variable NIL and in-kind compensation.
Related-Party Transactions Across Entities
As athletes become more sophisticated in managing multiple streams of income, some may establish business entities (such as LLCs or S corporations) to organize their affairs. While this can provide tax planning opportunities, it also introduces new audit risks. For example, the IRS may scrutinize related-party transactions for compliance with tax rules. The improper use of entity structures can result in disallowed deductions or reclassification of income. College athletes should consult with appropriate professional advisors, including attorneys and CPAs, to ensure that entities are properly formed, maintained, and operated in accordance with state and federal law.
Given the high-profile nature of the House v. NCAA settlement, the significant sums involved across college athletics, and the need to close governmental budget shortfalls, the IRS and state taxing authorities may be inclined to increase enforcement efforts targeting college athletes, their institutions, and even the third-party brands signing endorsement deals. Athletes must be proactive in their tax compliance to minimize the risk of audits and penalties.
- Employee v. Independent Contractor: Unsettled Status and Tax Implications
The House v. NCAA settlement failed to provide a definitive answer on athlete employment status. Whether college athletes are considered employees or independent contractors is a pivotal issue, as it fundamentally shapes their ability to collectively bargain. Moreover, it also affects the tax obligations, rights, and compliance responsibilities of both athletes and institutions.
The question of whether college athletes are employees or independent contractors is currently the subject of ongoing litigation, regulatory scrutiny, and legislative debate. The National Labor Relations Board previously signaled that certain college athletes may be considered employees under federal labor law.[3] And athletes at Dartmouth and Northwestern have sought to earn employee status through the creation of unionized teams. Yet many factors make earning employee status challenging, such as determining the degree of control universities have over athletes, the athlete’s economic independence from institutions, and definitional variations across states.
Tax Implications of Independent Contractor Classification
If athletes are treated as independent contractors, the following tax obligations, among others, apply:
- Self-Employment Tax: Athletes must pay both the employer and employee portions of Social Security and Medicare taxes (currently totaling 15.3%) on their net earnings, in addition to federal and state income taxes.
- Estimated Tax Payments: Without employer withholding, athletes may be responsible for making quarterly estimated tax payments to avoid underpayment penalties.
- Business Expense Deductions: Independent contractors may deduct ordinary and necessary business expenses, which could reduce their taxable income.
- Recordkeeping Requirements: The burden of maintaining detailed records falls on the athlete, who must substantiate all deductions in the event of an audit.
Tax Implications of Employee Classification
If athletes are classified as employees, then the tax implications change dramatically and include:
- Withholding and Reporting: Universities would be required to withhold federal and state income taxes, as well as FICA taxes (Social Security and Medicare), from athlete compensation. Athletes would receive a Form W-2 at year-end.
- Payroll Tax Compliance: The institution bears the responsibility for payroll tax compliance, reducing the risk of underpayment penalties for athletes but increasing administrative burdens on schools.
- Limited Deductions: Employees generally cannot deduct unreimbursed business expenses, such as training, travel, or equipment, due to the suspension of miscellaneous itemized deductions under the Tax Cuts and Jobs Act. Only expenses reimbursed by the school would be tax-free. That is, as independent contractors, athletes have more flexibility to deduct business expenses.
- Other Considerations: Other aspects of the relationship between a university and its student-athletes may be implicated if a student is also an employee. For example, if an athlete lives in university housing, is that value includable in the athlete’s gross income under IRC § 119? How would scholarships to student-athletes who are also employees be viewed with respect to the university’s tax-exempt status and prohibition on self-dealing?
Given the unsettled nature of the law, athletes and their advisors must monitor developments closely and be prepared to adapt their tax planning and compliance strategies as the landscape evolves.
III. How Whiteford Can Help: Navigating the New Tax Landscape
The House v. NCAA settlement ushers in a new era of opportunity—and complexity—for college athletes. Whiteford has extensive experience working with the IRS and state tax authorities to navigate multi-jurisdictional filing and residency issues, tax reporting problems, and any related penalties.
As the tax landscape for college athletes continues to evolve, proactive planning and expert guidance are essential. Our firm is committed to helping college athletes, their advisors, brands, and institutions minimize tax risks and compliance burdens.
Sports
Elyria Youth Track Club, Oberlin College Track and Field partner for clinic
The Elyria Youth Track Club, a program of the Elyria Youth Sports Club, is set to partner with Oberlin College Track and Field for a clinic.
The clinic will take place from 5-7 p.m. Jan. 7 at Oberlin College.
The clinic, open to all Elyria Youth Track athletes, will focus on showing young athletes fundamental and advanced techniques directly from Oberlin College Track and Field athletes and coaches, according to Aric Bowens, CEO of Elyria Youth Sports Club.
“I know last year, we went to an indoor track meet — our whole organization — and we got to meet Coach Izzy (Alexander, assistant coach for Oberlin College Track and Field),” Bowens said. “Since then, myself and Coach Izzy have been in communication with how can we get our kids infused with Oberlin College Track?”
According to Alexander, athletes participating in the clinic will learn a variety of skills and techniques in different stations at the college indoor track.
Youngsters will have exposure to different aspects of track through stations incorporating horizontal jumping into a sand pit, throwing shot puts, running sprints and relay racing, she said.
“This particular event is the first community event that we’re being involved with that specifically relates to track and field, so that’s something we’re really excited about,” Alexander said. “We hope to make it an annual event.”
With the clinic, Alexander said a vision is to help the youngsters feel more comfortable in their athletic ability, but also make them familiar with Oberlin College and the athletes they will interact with.
Athletes also can have a vision for what their future could look like if they wish to further their track career, Alexander said.
“If you can see it, you can be it,” she said. “They can realize that college and being a collegiate athlete is something that they can achieve, too, because they will have been more familiar with Oberlin.
“Track and field really has been a transformative part of our lives, and this event is kind of a way to give back and a way to foster continued participation.”
Alexander said the Oberlin College Track and Field team has continued to nurture its presence in the community by partnering with organizations like Oberlin Community Services, Oberlin Heritage Center and the Western Reserve Land Conservancy.
The Track and Field Clinic also marks a positive first step in a strong relationship with the Elyria Youth Track Club.
“We’re really thrilled to host this event,” Alexander said. “They’ve been really terrific to work with.”
Bowens said there are around 50 athletes in the Track Club who practice throughout the year, and participate in training like weight lifting and conditioning.
This “invaluable experience” for young track athletes will help strengthen their athletic ability, and connect them to different resources and organizations in Lorain County.
“I think it is an amazing opportunity,” Bowens said. “We’re super excited, just for this experience for our children.
“We would love to continue to keep the relationships going and growing for our organization.”
For more information, email elyriayouthsportsclub@gmail.com.
Sports
Men’s Volleyball Picked First in EIVA, Merk and Rose Named Players to Watch – Penn State
UNIVERSITY PARK, Pa. – Penn State was the unanimous pick to win the 2026 EIVA title in a vote of the conference’s coaches. The poll was released on Monday along with a list of Players to Watch, which included the Nittany Lions’ Ryan Merk and Owen Rose.
Penn State received all seven first-place votes to finish atop the preseason poll, coming in ahead of NJIT (34 points) and George Mason (32) in second and third. Rounding out the poll were Princeton (26), Charleston (22), Harvard (22), and Sacred Heart (11).
Princeton won last year’s regular season title, but Penn State put it together at the right time. The Nittany Lions swept all three matches in the EIVA Tournament to win the championship as the third-seeded team.
Merk is a three-time All-American for the Nittany Lions, earning second team recognition in as a sophomore and honorable mention status as a freshman and junior. The libero is a three-time first-team All-EIVA selection.
Rose was an AVCA honorable mention All-American as a sophomore in 2024. He is also a three-time All-EIVA selection, making the first team as a freshman and sophomore and the second team last season as a junior.
Merk and Rose are the team’s two captains this season.
Penn State opens the 2026 season with four straight home matches. The Nittany Lions host Mount Olive (Jan. 9), Manhattan (Jan. 10), St. Thomas Aquinas (Jan. 15), and Lewis (Jan. 17) during that stretch.
Sports
Nebraska finishes No. 3 in final AVCA Coaches Poll
LINCOLN, Neb. (KOLN) – Nebraska volleyball closed the season ranked No. 3 in the final AVCA Coaches Poll, finishing 33–1 after spending the entire season atop the rankings before the postseason.
Texas A&M rose to No. 1 in the final poll after winning the national championship over Kentucky. The Aggies earned 61 first-place votes and 1,525 points to finish 29–4, while Kentucky ends the year ranked second at 30–3 as the national runner-up.
Pittsburgh and Wisconsin round out the top five, with Wisconsin making a five-spot jump to finish No. 5. Creighton closes the season ranked No. 10 at 28–6, while Cal Poly enters the final Top 25 at No. 21 after being unranked last week.
Penn State fell out of the Top 25 despite receiving votes, marking the program’s first absence from the final poll since 1988 and ending a streak of 565 consecutive weeks ranked.
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Sports
Best Athens-area high school volleyball players for the 2025 season
Dec. 23, 2025, 4:02 a.m. ET
Next up for the fall all-area series is volleyball.
One Athens-area high school volleyball team made history this season as Oglethorpe County returned from Cartersville with its first ever state title. The 3-seeded Patriots defeated Bremen in the 1A championships, 3-1, to finish the season 32-8 overall.
In GHSA, Jefferson and Oconee County made it to the 3A quarterfinals, while Athens Academy, Jackson County and North Oconee were eliminated in their respective second rounds and Apalachee, Commerce, East Jackson and Prince Avenue Christian succumbed in their respective first rounds.
Sports
KSR Today: Volleyball Ends, Basketball Rolls On
Good morning, KSR readers. It’s Monday morning of Christmas week. Can you believe it? Ready or not, it’s here, so get that last-minute shopping in. Maybe I’ll see you out there, right after I get these decorations put up.
In addition to Christmas anxiety, we’re coming off an emotional weekend in Big Blue Nation. Sunday didn’t pan out the way we hoped in the NCAA Volleyball Final Four, but Saturday in Atlanta gave us some excitement with Mark Pope’s Wildcats finally getting a top-25 win in the CBS Sports Classic, leaning on the depth of a full roster.
There is more UK fun ahead, so what do you say we catch up on everything as the holidays close in? And let me know if you have any last-minute shopping ideas, or if you want to put the ornaments on my Christmas tree.
Kentucky Volleyball swept by A&M in the NCAA Championship
This one was tough to wrap your head around. Kentucky Volleyball‘s incredible season came to a disappointing end Sunday in Kansas City, as the Wildcats were swept 3-0 by Texas A&M in the NCAA Championship match. It never felt like this was how it was supposed to end. Kentucky had set point in the opening set at 24-23, but Texas A&M closed on a 3-0 run, and it was all Aggies from there.
The Wildcats struggled to find their rhythm after that moment during one of the worst performances of the season. A&M was the far better team for the afternoon and had the majority of the crowd, winning the final two sets 25-15 and 25-20. The loss snapped a 27-match winning streak and was a shocking finish for a team that had been so steady and dominant all season, and was favored to win.
Still, Craig Skinner’s NCAA runner-up group deserves appreciation. Kentucky finishes 30-3, swept the SEC regular season and tournament titles, and reached the national championship for the second time in program history. Yeah, the ending hurt, but the Wildcats brought a lot of joy and excitement to the fan base, and the program is built to be back on this stage again next season. Sunday’s final still stings for now, though.
Mark Pope’s Wildcats host Bellarmine in Rupp Arena tomorrow
Now at full strength, Kentucky Basketball returns to Rupp Arena tomorrow for a pre-Christmas matchup with Bellarmine, looking to keep momentum rolling before the short holiday break. The Wildcats have won three straight games, including wins over Indiana and St. John’s, and are starting to look more comfortable on both ends of the floor after a disappointing start to the year.
Bellarmine, ranked No. 260 in KenPom, catches Kentucky at a bad time. However, the Knights also snapped out of a recent funk with a 15-point win over Chattanooga. Bellarmine is 5-6 entering Tuesday’s game, set for 1 p.m. in the afternoon. It’s a streaming-only game on SEC Network+.
Q&A with Jayden Quaintance and Kam Williams
Fresh off his Kentucky debut, Jayden Quaintance gets a turn at the podium to preview Kentucky’s next game. He and Kam Williams, who also starred in Saturday’s comeback win, will take questions about the matchup with Bellarmine and the upcoming holiday break. You can watch those conversations here at KentuckySportsRadio.com later today.
Hear from Mark Pope during his call-in show
After Quaintance and Williams speak for the locker room, Mark Pope will sit down with Tom Leach for his Monday night call-in radio show. Hear from Pope at 6 p.m. on the UK Sports Network, as he recaps the win over St. John’s and more on the team’s three-game winning streak.
Kentucky climbing the NET, maybe the Top 25
With Saturday’s win, Kentucky climbed the NET Rankings up to No. 23. Later today, we’ll find out if the win was enough to move the Wildcats back into the Top 25 polls. The AP and Coaches’ polls update around lunchtime for both men’s and women’s college basketball. Kenny Brooks’ squad enters the new week ranked No. 12/13.
Will Stein’s first coaching staff is taking shape
Will Stein is a busy man, balancing two jobs this holiday season. On Saturday, his Oregon Ducks scored 51 points in their first College Football Playoff game. Then on Sunday, news spread of Stein’s latest hire for his first staff in Lexington.
Former Cal assistant Allen Brown will serve as Kentucky Football‘s cornerbacks coach. Brown replaces Chris Collins, who joins Brad White and Jon Sumrall at Florida, and rounds out Stein’s list of assistant coaches for his first season at UK:
- Joe Sloan: Offensive Coordinator
- Jay Bateman: Defensive Coordinator
- Cutter Leftwich: Offensive Line
- Kolby Smith: Running Backs
- Justin Burke: TBA
- Joe Price III: Wide Receivers
- Josh Christian-Young: Safeties
- Anwar Stewart: Defensive Line
- Tony Washington Jr: Pass Rushers
- Allen Brown: Cornerbacks
Former Cal assistant to coach Kentucky’s cornerbacks
Tune in to KSR at 10 a.m.
Matt Jones hosts today’s show from New Orleans, where he will call his first football game for ESPN Radio tomorrow. Joining him via technology are Ryan Lemond and me in Lexington, and Shannon The Dude in Louisville. Together, we’ll recap the high and low weekend from 10 a.m. to noon. Go Cats.
Sports
South Dakota earns three Summit League Academic All-League selections
SIOUX FALLS, S.D. — South Dakota volleyball’s Avery Van Hook, Kamryn Farris and Amanda Loschen were named to the Summit League Volleyball Academic All-League team, announced the league office Monday.
South Dakota accounted for three of the seven spots on the Academic All-League team and was the only program to have multiple athletes named to the team. Van Hook has been named to the Academic All-League Team in consecutive seasons, while Farris and Loschen appeared on the team for the first time in their career.
The three Coyotes were also named to the 2025 CSC Academic All-District Team.
To be eligible for the Academic All-League team, a student-athlete must have a cumulative GPA of at least 3.30 (on a 4.0 scale), completed at least one full academic year at the current institution and participated in 50 percent of their team’s competitions.
Nominations are brought forth by sports information directors from the league’s participating members, and voting is conducted by both SIDs and FARs. The teams are made up of ten student-athletes receiving the most votes with all ties standing.
2025 Summit League Volleyball Academic All-League Team
| Name | School | Yr. | Pos. | GPA | Major |
| Ally Barth | NDSU | Sr. | MB | 3.94 | Management Communication |
| Kamryn Farris | South Dakota | Sr. | DS | 3.75 | Business |
| Avery Van Hook** | South Dakota | Jr. | S | 3.87 | Kinesiology & Sport Management |
| Kali Jurgensmeier** | Omaha | Sr. | OH | 3.82 | Biology |
| Amanda Loschen | South Dakota | Jr. | MB | 3.86 | Medical Biology |
| Lauren Perugini** | North Dakota | Jr. | OH | 4.00 | Dietetics |
| Joslyn Richardson** | SDSU | Jr. | DS | 4.00 | Construction Management |
*Career Academic All-League honors
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