The “jock tax” remains one of the most complex and strategically significant areas of U.S. state income taxation, particularly for NFL players, NBA players, MLB athletes, and other high-income professional athletes whose compensation is allocated across multiple states.
Professional athletes earn substantial compensation, yet their exposure to U.S. state income tax can dramatically reduce net earnings. The so-called “jock tax” refers to state income tax imposed on nonresident professional athletes for income earned while performing services within a taxing state. For NFL players and other professional athletes, the jock tax can trigger filing obligations in numerous states during a single season.
In the 2026 NFL season, quarterback Sam Darnold — leading the Seattle Seahawks — guided his team to a decisive victory in Super Bowl LX, defeating the New England Patriots 29–13, showcasing how top-tier players are nonetheless subject to complex multi-state tax rules. Darnold’s status as an NFC championship starter and Super Bowl winner highlights both the competitive and tax implications for highly compensated NFL quarterbacks.
What Is the Jock Tax Under U.S. State Income Tax Law?
The jock tax is not a separate federal tax. Rather, it is the application of ordinary state income tax principles to nonresident professional athletes.
States that impose personal income tax generally tax:
- Residents on worldwide income
- Nonresidents on income sourced to that state
For professional athletes, most states apply a duty-day allocation formula. Under this method:
- The numerator equals duty days spent performing services in the taxing state
- The denominator equals total duty days during the season
The resulting fraction is multiplied by total compensation to determine state-source income subject to that state’s income tax.
For NFL players, total duty days often approximate 160 to 180 days per season, depending on training camp, regular season, playoffs, and Super Bowl appearances. Even a handful of in-state duty days can result in significant taxable income allocation when total compensation reaches eight figures.
California’s Jock Tax: A High-Tax Jurisdiction Example
California imposes one of the highest top marginal state income tax rates in the United States, currently 13.3% for high-income earners. For elite NFL players earning tens of millions of dollars annually, California’s jock tax can produce six-figure state income tax liabilities from a limited number of appearances.
Using the Sam Darnold scenario as an illustration:
- Estimated total football compensation: approximately $33 million
- Hypothetical California duty days: five regular-season days plus ten Super Bowl-related days
- Total assumed duty days: 170
If 15 out of 170 duty days are allocated to California, approximately 8.8% of total compensation becomes California-source income. On $33 million, that allocation produces nearly $2.9 million of California-taxable income.
At a 13.3% California income tax rate, the resulting California state income tax may approach $385,000 — before considering playoff bonuses and Super Bowl bonuses.
Importantly:
- Super Bowl bonuses earned in California are generally treated as California-source income.
- Media days and preparation days count toward duty days.
- Even if no incremental base salary is paid for postseason games, the duty-day formula increases California allocation.
This is how the California jock tax can meaningfully impact an NFL player’s after-tax income.
Why NFL Players in No-Income-Tax States Face Greater Exposure
NFL players domiciled in no-income-tax states — such as Washington, Texas, Florida, or Nevada — face unique multi-state tax consequences.
Most states provide a credit for taxes paid to another state. However:
- The credit is limited to the tax otherwise payable in the home state.
- If the home state has no income tax, there is no offsetting credit.
For a Washington-based quarterback, California jock tax payments cannot be offset by Washington income tax, because Washington does not impose a personal income tax. As a result, the California state income tax becomes a direct economic cost.
This feature of multi-state income taxation is central to the jock tax analysis for professional athletes.
Federal Tax Implications: The SALT Deduction Limitation
At the federal level, state and local income taxes are deductible only as an itemized deduction, subject to the $10,000 SALT cap.
For high-income professional athletes:
- State income tax payments may exceed several hundred thousand dollars.
- Only $10,000 of those state income taxes may be deducted for federal income tax purposes.
The federal SALT limitation significantly reduces the federal tax benefit of state income tax payments arising from jock tax exposure.
Can a Super Bowl Appearance Create Adverse Tax Results?
Commentators occasionally suggest that an athlete could face a marginal tax rate exceeding 100% on certain allocated income. While such outcomes are generally theoretical rather than literal, distortions can arise because:
- Base salary structures implicitly anticipate postseason play.
- Duty-day formulas allocate income to playoff states even if no additional salary is paid.
- Super Bowl bonuses are taxed in the state where the game is played.
The interaction between state income tax allocation rules, bonus structures, and federal tax limitations can create unexpected results in high-tax jurisdictions such as California.
Multi-State Tax Compliance Burdens for Professional Athletes
The jock tax does not apply solely to star quarterbacks. It also affects:
- Backup players
- Coaches and trainers
- Team staff traveling with the franchise
Each may be required to file multiple nonresident state income tax returns annually. For NFL players and other professional athletes, multi-state tax compliance can be administratively complex and costly.
Strategic Jock Tax Planning for NFL Players and High-Income Athletes
Effective tax planning requires careful coordination among advisors and experienced, knowledgeable, and seasoned California tax lawyers who understand multi-state income tax allocation rules.
Planning considerations may include:
- Evaluating domicile before signing long-term contracts
- Reviewing signing bonus sourcing rules
- Analyzing endorsement income allocation
- Monitoring duty-day calculations in high-tax states
- Coordinating federal and state tax strategy to manage SALT limitations
Failure to properly plan for jock tax exposure can result in unexpected state income tax liabilities, penalties, and interest.
Conclusion: The Real Cost of the Jock Tax
The jock tax highlights how state income tax rules can materially reshape headline compensation for NFL players and other professional athletes. A Super Bowl victory may elevate an athlete’s brand and long-term earning potential, but high-tax jurisdictions like California can significantly impact short-term after-tax income.
For professional athletes earning income across multiple states, proactive state income tax planning is essential. The intersection of duty-day allocation formulas, state tax credits, domicile rules, and federal SALT limitations creates a sophisticated multi-state tax environment requiring experienced, knowledgeable, and seasoned tax lawyers to manage risk effectively.
Tax Tips
- Track duty days carefully in every taxing jurisdiction.
- Review state income tax allocation rules before contract execution.
- Analyze home-state credit limitations if domiciled in a no-income-tax state.
- Consider the federal SALT cap when modeling after-tax income.
- Engage experienced, knowledgeable, and seasoned US tax lawyers for multi-state income tax planning.
FAQ
What is the jock tax?
The jock tax is the application of state income tax rules to nonresident professional athletes based on income earned in a specific state.
Do all states impose a jock tax?
Only states with a personal income tax impose jock tax obligations. No-income-tax states do not.
How is NFL income allocated among states?
Most states use a duty-day allocation formula comparing in-state duty days to total season duty days.
Does living in a no-income-tax state eliminate jock tax liability?
No. Visiting states may still tax income earned within their borders, and home-state credits may not offset the liability.
Does the federal government impose a jock tax?
No. However, federal income tax applies to total income, and the SALT deduction for state income taxes is capped.
DISCLAIMER: This article provides broad information. It is only accurate as of the posting date. It has not been updated and may be out-of-date. It does not give legal advice and should not be relied on as tax advice. Every tax scenario is unique to its circumstances and will differ from the instances described in the article. If you have specific legal questions, you should seek the advice of experienced, knowledgeable, and seasoned US tax lawyers.