For decades, college athletes have benefited from scholarship-funded education and stipends but were otherwise unable to share in the billions of dollars in annual revenue generated from athletic programs by the NCAA.
The 2021 landmark Supreme Court ruling in NCAA v. Alston changed that by holding that the NCAA could not restrict education-related benefits for athletes, effectively legalizing their ability to earn compensation from their name, image, and likeness (NIL).
This ruling opened the door for student athletes to earn a potentially significant amount of money during their college careers from marketing, appearances, and licensing deals, making personal estate and financial planning considerations even more important for student athletes.
From basic but crucial estate planning documents that every athlete should have to more sophisticated tax and financial planning tailored to those benefiting from NIL, the following are important considerations to address the unique needs and career trajectories of athletes to protect them and their earnings.
Necessary Planning for All Student Athletes
Patient Advocate Designation and Living Will
While every young adult should have a Patient Advocate Designation and Living Will, athletes are at increased risk of serious injury.
- A Patient Advocate Designation allows the athlete to name an individual to act on their behalf with respect to medical decisions.
- A Living Will details what type of care they would like to receive under certain circumstances, including end-of-life wishes surrounding end-of-life care.
Without this document, a guardian would need to be formally appointed by the probate court to make these decisions, adding stress and wasting time during an already difficult situation. A Patient Advocate Designation and Living Will are the bare minimum that every athlete should have once they turn 18 years old.
Durable Power of Attorney
The Durable Power of Attorney is a document that allows someone else (the “agent”) to make legal and financial decisions on the athlete’s behalf. These documents can be structured so they are effective immediately upon signing or only upon incapacity. As most student athletes will be over age 18, they are legally adults and must transact on their own (e.g., signing insurance documents, endorsement deals, etc.). Great care must be given to selecting an agent, particularly if the athlete has significant assets or fame, as the agent will have the same authority as the athlete over their assets.
Similar to the Patient Advocate Designation, in the event of incapacity, a conservator would need to be appointed by the probate court to make these decisions for the athlete if a Durable Power of Attorney is not in place. Also note that the athlete’s agent under Durable Power of Attorney is distinguishable from the athlete’s “Agent” who represents the athlete in contract negotiations for their employment and other endorsement or sponsorship opportunities. However, the athlete could choose the same person to fulfill both roles, if appropriate under the circumstances.
Income Taxes
Athletes compete all over the country and, in some cases, the world. From an income tax perspective, athletes need to be aware of earning income in multiple states (or countries) and carefully track this, as additional tax filings may be required (and additional taxes may be owed).
Additional Considerations for Athletes Benefitting from NIL
Few student athletes will make it to the professional ranks, and NIL earnings may be the financial pinnacle of their athletic careers. For those who do end up playing at the professional level, the odds are stacked against long-term financial success: most professional careers end in under five years, and many of these athletes face serious financial issues or bankruptcy shortly after they stop playing.
Developing a strategy with a team of trusted advisors (attorney, accountant, agent, financial advisor) is the key to success for athletes who have limited time to spare outside of training and who experience unique needs, including risk of a career-ending injury, a few peak years for earning that must last for decades, and greater risk of being targeted for their wealth. This strategy should include additional estate planning documents, financial and tax planning advice, and a discussion of asset protection and privacy concerns.
Revocable Trusts
The use of revocable trust planning is a great place to start for younger athletes, especially those in the wealth accumulation phase of their lives. Trusts can provide an additional layer of security against any third parties who may try to take advantage of the athlete, especially when using a professional or other reliable individual as trustee. Trusts can also provide terms that would allow the athlete to grow with their wealth and learn to manage it in a responsible way by limiting distributions to things that are necessary, like medical, health, or housing expenses. Privacy is another advantage, as a trust does not have to carry the name of the person who created it. Thus, a trust can house assets without being tied back to an individual. In the event of the athlete’s death, the assets would pass outside of probate court, further preserving privacy, to whomever the athlete has named as beneficiary.
Estate and Gift Tax Planning
When coming into wealth, it is tempting to gift money or items (e.g., homes, cars, watches, etc.) to those people who supported the athlete while they were up-and-coming. However, athletes should be mindful of not only the constraint on their assets but also the tax impact of making these gifts, especially larger ones.
Currently, any person can gift up to $19,000 to any other individual without filing a gift tax return. Anything with a greater value than that amount will require filing a gift tax return, though tax may not be due. Further, anything reported on the gift tax return reduces an individual’s lifetime exemption for estate tax purposes.
If the athlete has wealth that would support large gifting, utilizing irrevocable trusts to receive those assets could be a good planning option. While there is generally a filing requirement for gift tax purposes (and an exemption used), once the assets are in the trust, they are inherently more protected and could be structured to last for several generations. Assets could also be invested to provide additional growth for beneficiaries, and future appreciation on the assets of the irrevocable trust would occur outside of the athlete’s gross estate for estate tax purposes, representing additional estate tax savings.
Asset Protection
In several states, including Michigan, there are Domestic Asset Protection Trusts (DAPTs) that can be set up for maximum creditor protection. These trusts offer strong creditor protection while allowing the grantor to receive discretionary distributions, direct investments, and set terms for the trust’s ultimate disposition. There are also downsides to DAPTs, mostly that the assets are not easily accessible, the grantor is giving up control over assets to a trustee, and the trust is irrevocable and not readily changeable. DAPTs are often utilized by people with substantially risky careers who are exposed to liability.
Protecting NIL Wealth for a Lifetime
Athletes now earn at a high level during their college years. These income streams could last well past college and even leave a lasting legacy. Student athletes need a trusted team of advisors to help ensure they are doing everything they can to earn, protect, grow, and be tax-efficient with their assets. Having that structure in place will help the wealth last through the athlete’s life and protect it for future generations.
Varnum continually monitors NIL activity at the federal, state, and institutional levels and helps students protect their interests. Contact a member of our NIL Practice Team or our Estate Planning Practice Team for assistance with NIL questions or estate planning for athletes with NIL arrangements.
This advisory was originally published on September 8, 2022, and updated on October 24, 2025.