II 

117TH CONGRESS 

1ST SESSION S. 2897 

To amend the Internal Revenue Code of 1986 to provide that the exclusion 

from gross income for qualified scholarships does not apply to athletic 

scholarships if the recipient receives certain income derived from the 

recipient’s name, image, or likeness. 

IN THE SENATE OF THE UNITED STATES 

SEPTEMBER 29, 2021 

Mr. BURR introduced the following bill; which was read twice and referred to 

the Committee on Finance 

A BILL 

To amend the Internal Revenue Code of 1986 to provide 

that the exclusion from gross income for qualified scholarships does not apply to athletic scholarships if the 

recipient receives certain income derived from the recipient’s name, image, or likeness. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘NIL Scholarship Tax 

5 Act’’. 


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•S 2897 IS

1 SEC. 2. TREATMENT OF CERTAIN ATHLETIC SCHOLAR2 SHIPS AS INCOME. 

3 (a) IN GENERAL.—Section 117(c) of the Internal 

4 Revenue Code of 1986 is amended to read as follows: 

5 ‘‘(c) LIMITATIONS.— 

6 ‘‘(1) TEACHING SERVICES.— 

7 ‘‘(A) IN GENERAL.—Except as provided in 

8 subparagraph (B), subsections (a) and (d) shall 

9 not apply to that portion of any amount re10 ceived which represents payment for teaching, 

11 research, or other services by the student re12 quired as a condition for receiving the qualified 

13 scholarship or qualified tuition reduction. 

14 ‘‘(B) EXCEPTIONS.—Subparagraph (A) 

15 shall not apply to any amount received by an 

16 individual under— 

17 ‘‘(i) the National Health Service 

18 Corps Scholarship Program under section 

19 338A(g)(1)(A) of the Public Health Serv20 ice Act, 

21 ‘‘(ii) the Armed Forces Health Profes22 sions Scholarship and Financial Assistance 

23 program under subchapter I of chapter 

24 105 of title 10, United States Code, or 

25 ‘‘(iii) a comprehensive student work26 learning-service program (as defined in 


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•S 2897 IS

1 section 448(e) of the Higher Education 

2 Act of 1965) operated by a work college 

3 (as defined in such section). 

4 ‘‘(2) CERTAIN ATHLETIC SCHOLARSHIPS.— 

5 ‘‘(A) IN GENERAL.—Subsection (a) shall 

6 not apply to any athletic scholarship if— 

7 ‘‘(i) the individual receiving such ath8 letic scholarship received income in excess 

9 of $20,000 during the taxable year from 

10 the name, image, or likeness of such indi11 vidual, or 

12 ‘‘(ii) this paragraph applied to such 

13 athletic scholarship for any prior taxable 

14 year. 

15 ‘‘(B) ATHLETIC SCHOLARSHIP.—For pur16 poses of this paragraph, the term ‘athletic 

17 scholarship’ means any qualified scholarship the 

18 terms of which require the recipient to partici19 pate in a program of intercollegiate athletics at 

20 an institution of higher education (as defined in 

21 section 102 of the Higher Education Act of 

22 1965 (20 U.S.C. 1002)) in order to be eligible 

23 to receive such assistance.’’. 


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•S 2897 IS

1 (b) EFFECTIVE DATE.—The amendment made by 

2 this section shall apply to taxable years beginning after 

3 the date of the enactment of this Act. 

Æ 


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