S. 1454 – Athlete Opportunity and Taxpayer Integrity Act

AI-Generated Summary

Updated January 20, 2026 at 7:07 AM UTC

The Athlete Opportunity and Taxpayer Integrity Act changes the tax code so that donors cannot claim a charitable deduction for contributions that are used to pay college athletes for the use of their name, image, or likeness. The rule applies to any charitable contribution where any part of the money goes to a secondary or post‑secondary school athlete for that purpose. An exception is kept for contributions made directly to an eligible educational institution. The change takes effect for tax years beginning after the law is enacted.

Key Provisions

Disallows a charitable deduction for contributions used to compensate college athletes for their name, image, or likeness.
Provides an exception for contributions made directly to an eligible educational institution, which remain deductible.
Makes conforming amendments to related tax code language (Section 63(b)) to align with the new rule.
Effective for contributions in taxable years beginning after enactment.

Legislative Activity

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1 earlier action

SenateIntro Referral Latest Action

Read twice and referred to the Committee on Finance. (text: CR S1536)

Finance Committee

May 4, 2023

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SenateIntro Referral

Introduced in Senate

May 4, 2023

SenateIntro Referral

Read twice and referred to the Committee on Finance. (text: CR S1536)

Finance Committee

May 4, 2023

Floor Debate

2 members

What members said about S. 1454 on the floor

1 Republican1 Democrat

Sen. John ThuneR-SD · May 4, 2023

Madam President, I ask unanimous consent that the text of the bill be printed in the Record.

Sen. Richard J. DurbinD-IL · May 4, 2023

Madam President, I ask unanimous consent that the text of the bill be printed in the Record.

Sen. John ThuneR-SD · May 4, 2023

Madam President, I ask unanimous consent that the text of the bill be printed in the Record.

Bill Text

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Introduced in SenateIssued May 4, 2023

II

118th CONGRESS

1st Session

S. 1454

IN THE SENATE OF THE UNITED STATES

May 4, 2023

Mr. Thune (for himself and Mr. Cardin) 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 disallow a deduction for charitable contributions for certain purposes relating to college athletics.

1.

Short title

This Act may be cited as the Athlete Opportunity and Taxpayer Integrity Act.

2.

Disallowance of deduction for contributions for certain purposes relating to college athletics

(a)

In general

Subsection (p) of section 170 of the Internal Revenue Code of 1986 is amended to read as follows:

(p)

Contributions for certain purposes relating to college athletics

(1)

In general

No deduction shall be allowed for any contribution any portion of which is used by the donee to compensate 1 or more secondary or post-secondary school athletes for the use of their name, image, or likeness by reason of their status as athletes.

(2)

Exception

Paragraph (1) shall not apply to any contribution made directly to an organization which is an eligible educational institution (as defined in section 25A(f)(2)).

.

(b)

Conforming amendments

Section 63(b) of the Internal Revenue Code of 1986 is amended by inserting and at the end of paragraph (2), by striking , and at the end of paragraph (3) and inserting a period, and by striking paragraph (4).

(c)

Effective date

The amendments made by this section shall apply to contributions made in taxable years beginning after the date of the enactment of this Act.