Talent licenses name/image/likeness to a separate IP holding company that receives royalties, isolates from liability.
Advanced structure: talent transfers/assigns NIL rights to a separate IP HoldCo (S-corp, LLC, or in some cases foreign IP holdco) which then licenses those rights back to the operating loan-out or directly to brands. Royalty income to IP HoldCo can be structured for: (1) family-member ownership (income shift), (2) different state domicile, (3) potential §199A QBI, (4) IP is asset-protected from operating liability, (5) at exit/retirement, sale of the IP entity may qualify for capital gains treatment (vs ordinary comp).
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Talent forms an S-corp or C-corp that 'loans out' services — routes income through corp for retirement + benefit optimization.
Athletes/entertainers taxed by each state they perform in — establish no-tax domicile + optimize duty-day allocation.
College athletes form LLCs for NIL income, deduct training/travel/agent, fund Roth IRA on earned income.
Actors/musicians earning under $16K from performing get above-line deduction for job expenses (bypasses TCJA suspension).
YouTubers/TikTokers/streamers deduct home studio, equipment, subscriptions, travel, and half of new gear via §179.
On-tour entertainers use IRS high-low per diem (~$309/day) for meals/lodging without receipts — full deduction.
Structure signing bonus as compensation for SIGNING (not future services) to allocate to home-state domicile, not team state.
Structure endorsement deals as receipt of depreciable equipment/vehicles rather than cash — different tax profile.